Case Digest (G.R. No. 233988) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines represented by the Manila International Airport Authority (MIAA) v. Spouses Nocom et al. (G.R. No. 233988, November 15, 2021), MIAA initiated expropriation proceedings on January 25, 1982 (Civil Case No. 9712-P) to expand Ninoy Aquino International Airport by acquiring Lots 2817, 2818, and 2819 in Parañaque, originally owned by Emiliano Cruz. A Writ of Possession issued on January 24, 1983, and in 1991 the Regional Trial Court (RTC) of Makati confirmed expropriation, awarding just compensation at ₱552.00/sq.m. plus 6% interest from 1983 until full payment. While MIAA’s appeal before the Court of Appeals (CA) was pending, it subdivided the lots and successfully moved in 1992 to exclude all but Lot 2817-B from the expropriation judgment. Meanwhile, the Land Registration Court registered the lots in the names of Cruz’s heirs, who then sold them to Spouses Mariano and Anacoreta Nocom and Spouses Sy Ka Kieng and Rosa Chan, giving rise to Transfer Certif Case Digest (G.R. No. 233988) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Expropriation Proceedings
- On January 25, 1982, the Manila International Airport Authority (MIAA) filed Civil Case No. 9712-P to expropriate Lots 2817, 2818, and 2819 in Ibayo, Parañaque, for NAIA expansion.
- January 24, 1983 – RTC Pasay issued Writ of Possession; 1991 – case transferred to RTC Makati; June 21, 1991 – expropriation confirmed, just compensation fixed at ₱552.00/sqm plus 6% interest from 1983 until full payment.
- Exclusion, Titling, and Sale
- While appeal was pending, MIAA subdivided each lot into “-A” and “-B” parcels; moved to exclude all except Lot 2817-B; CA granted motion on July 21, 1992.
- Heirs of Emiliano Cruz obtained Torrens registration (OCT 239, 246), sold to Spouses Nocom and Spouses Sy–Chan; TCT 74961 and 74962 were issued.
- Recovery and Annulment Actions
- August 12, 2009 – Spouses Nocom filed Civil Case No. 09-0276 (Recovery of Possession and Accounting) claiming non-payment of compensation and seeking rentals for Lots 2817-B, 2818-B, and 2819-B.
- MIAA filed Civil Case No. 10-0064 (Annulment of Titles); both cases consolidated. May 11, 2015 – RTC Parañaque denied recovery of possession but awarded ₱41.24 M rentals + 12% interest; dismissed MIAA’s annulment suit. August 7, 2015 – partial reconsideration excluded Lot 2817-B from owners’ properties.
- Court of Appeals and Supreme Court Proceedings
- April 19, 2017 – CA affirmed with modification: total rentals reduced to ₱41.24 M broken into periods, interest rates of 12% and 6%, plus monthly rentals from January 2015.
- MIAA petitioned the Supreme Court, arguing lack of jurisdiction (sovereign immunity, res judicata), propriety of rental award, and indefeasibility of titles.
Issues:
- Did the CA commit grave abuse in allowing the civil complaint despite MIAA’s claim of sovereign immunity and res judicata?
- Was MIAA’s use of the lots an exercise of proprietary (jure gestionis) function entitling it to treat the occupation as a lease?
- Are the respondents entitled to rental payments and interest, or must MIAA pay just compensation with appropriate interest?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)