Case Digest (G.R. No. 199161) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines v. Spouses Alforte (G.R. No. 217051, August 22, 2018), Cornelio and Susana Alforte owned a 300-square-meter lot in Mabulo, Naga City, covered by Transfer Certificate of Title No. 29597. The land originated from a March 21, 1956 free patent under Commonwealth Act No. 141 (the Public Land Act). The Department of Public Works and Highways (DPWH) proceeded with the Naga City-Milaor Bypass Road project, which traversed 127 square meters of the Alfortes’ property. The spouses filed Civil Case No. 2012-0013 before the Regional Trial Court (RTC) of Naga City, Branch 22, seeking just compensation of ₱381,000 plus attorney’s fees and litigation expenses. DPWH answered, invoking Section 112 of CA 141, as amended by PD No. 1361, which imposes a perpetual easement of right-of-way up to 60 meters in width over lands granted by patent, with payment of damages for improvements only. The RTC in a Partial Decision dated July 28, 2014 held that the Alfortes were enti... Case Digest (G.R. No. 199161) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Petitioners: Republic of the Philippines, represented by the Department of Public Works and Highways (DPWH), Engr. Rebecca J. Roces (District Engineer) and Engr. Victorino M. Del Socorro, Jr. (Project Engineer).
- Respondents: Spouses Cornelio and Susana Alforte, registered owners of a 300-square-meter parcel covered by TCT No. 29597, originally issued under a March 21, 1956 Free Patent and April 14, 1956 Original Certificate of Title No. 235 pursuant to Commonwealth Act No. 141 (Public Land Act).
- Road Project and Expropriation Proceedings
- DPWH’s Naga City–Milaor Bypass Road will traverse 127 sq.m. of respondents’ land.
- Respondents filed Civil Case No. RTC 2012-0013 seeking just compensation of ₱381,000 for the affected area, plus attorney’s fees and litigation expenses.
- Petitioners answered, invoking Section 112 of CA 141 (as amended by PD No. 1361) imposing a 60-meter-wide right-of-way easement in favor of the Government without compensation except for affected improvements, and Section 44 of PD 1529 on statutory liens.
- Trial Court Dispositions
- July 28, 2014 Partial Decision (RTC Branch 22, Naga City):
- Held respondents entitled to just compensation despite CA 141’s easement;
- Ordered re-opening for determination of just compensation, deposit of assessed value (₱190,500), and appointment of three commissioners.
- March 3, 2015 Order: Denied petitioners’ motion for reconsideration, reiterating that the easement width (60 m) did not cover the 127 sq.m. taken and that constitutional due process and just-compensation guarantees prevail.
Issues:
- Entitlement to Just Compensation
- Whether respondents, as owners of land originally acquired by free patent, are precluded from claiming just compensation by the perpetual 60-meter right-of-way easement under Section 112 of CA 141.
- Whether judicial precedents (NIA v. CA; Republic v. Andaya) uphold the Government’s easement without compensation.
- Scope of the Easement and Taking
- Whether the 60-meter “width” limitation in Section 112 refers to linear width rather than area, rendering the trial court’s 127 sq.m. calculation erroneous.
- Whether the enforced easement results in practical destruction or material impairment of the remaining property, thus constituting a taking requiring compensation.
- Exhaustion of Administrative Remedies
- Whether respondents were required to exhaust administrative remedies (e.g., Commission on Audit) before judicial filing.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)