Case Digest (G.R. No. 233988)
Facts:
Republic of the Philippines represented by the Manila International Airport Authority (MIAA) v. Spouses Mariano Nocom and Anacoreta O. Nocom, Spouses Sy Ka Kieng and Rosa Chan, and others, G.R. No. 233988, November 15, 2021, the Supreme Court Third Division, Leonen, J., writing for the Court.The dispute concerns Lots No. 2817, 2818 and 2819 (the Subject Lots) in Ibayo, Paranaque, originally owned by Emiliano Cruz. On January 25, 1982 the Manila International Airport Authority (MIAA) initiated expropriation proceedings (Civil Case No. 9712‑P) to acquire lands for expansion of Ninoy Aquino International Airport (NAIA). A writ of possession issued January 24, 1983; in 1991, following judicial reorganization, the case was transferred to the Regional Trial Court (RTC) of Makati which on June 21, 1991 confirmed the expropriation and ordered payment of just compensation of P552.00/sq.m. plus 6% interest from 1983 until full payment. MIAA appealed to the Court of Appeals and, while appeal was pending, subdivided the Subject Lots; a MIAA motion to exclude five of the subdivided parcels from the expropriation judgment was granted by the Court of Appeals in a July 21, 1992 Resolution, leaving only Lot 2817‑B within the 150‑meter clearance zone.
Separately, acting as a land registration court, the RTC granted registration of the Subject Lots in the names of the heirs of Cruz; Original Certificates of Title (OCTs) were issued and later cancelled when the heirs sold the lots to the Spouses Nocom and the Spouses Sy/Chan, resulting in Transfer Certificates of Title (TCTs) Nos. 74961 and 74962. The Court of Appeals affirmed the expropriation court’s just compensation ruling on December 27, 1993; that decision became final January 29, 1994.
On August 12, 2009 the Spouses Nocom filed Civil Case No. 09‑0276 in the RTC of Paranaque for Recovery of Possession and Accounting, alleging MIAA never paid just compensation and remained in possession of Lots 2817‑B, 2818‑B and 2819‑B (the parcels at issue). MIAA denied liability and filed Civil Case No. 10‑0064 seeking annulment of the Nocoms’ titles. The two cases were consolidated. After trial, the RTC (Branch 257, Paranaque) issued a May 11, 2015 decision denying recovery of possession but ordering MIAA to pay P41,243,558.40 as rentals for the Subject Lots from December 19, 1995 to December 2014 plus 12% interest and specified monthly rentals thereafter; the RTC also dismissed MIAA’s annulment suit for lack of jurisdiction. On August 7, 2015 the RTC partially granted reconsideration by excluding Lot 2817‑B from the properties deemed owned by the heirs of Cruz for purposes of computing rentals.
MIAA appealed to the Court of Appeals under Rule 42, arguing procedural defects (jurisdictional defects due to allegedly unpaid docket fees, lack of cause of action, non‑exhaustion of administrative remedies, laches) and substantive defenses (res judicata and sovereign immunity), and contesting the indefeasibility of the respondents’ titles. On April 19, 2017 the Court of Appeals affirmed with modification, ordering payment of specified rental amoun...(Pro-only)
Issues:
- Was the RTC’s exercise of jurisdiction over respondents’ civil suit proper despite petitioner’s invocation of sovereign immunity and res judicata?
- Was petitioner’s use of the Subject Lots an exercise of a proprietary (jure gestionis) function or of a governmental/eminent domain (jure imperii) function?
- Are respondents entitled to rental payments and interest, and if so, what form and measu...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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