Case Digest (G.R. No. 172242) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In April 2011, the Department of Public Works and Highways (DPWH), through the Second Engineering District of Camarines Sur, notified spouses Ildefonso B. Regulto and Francia R. Regulto, registered owners under Transfer Certificate of Title No. 086-2010000231, of its plan to construct the Naga City–Milaor Bypass Road across 162 square meters of their 300-sqm lot in Mabel, Naga City, Camarines Sur. The lot had been acquired in 1994 by deed of sale from the Santos spouses and originated from a 7,759-sqm tract covered by Original Certificate of Title No. 235 issued upon a 1956 free patent under Commonwealth Act No. 141. DPWH initially offered ₱243,000 (₱1,500/sqm) but later withdrew, asserting that CA 141 and its amendments reserved a 60-meter government easement for public highways, entitling owners only to damages for improvements. The Regultos protested, insisting their property was private and demanding just compensation based on its fair market value and BIR zonal valuation. O Case Digest (G.R. No. 172242) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Property Ownership and Origin
- Spouses Ildefonso B. Regulto and Francia R. Regulto are registered owners of a 300 m² parcel in Mabel, Naga City, Camarines Sur (TCT No. 086-2010000231), acquired by deed of sale in February 1994.
- The parcel originated from a 7,759 m² tract granted under Free Patent (OCT No. 235, April 14, 1956), thus subject to Commonwealth Act (C.A.) No. 141 reservations and easements.
- Government Project and Initial Proceedings
- In April 2011, DPWH notified the Spouses Regulto that the Naga City–Milaor Bypass Road would traverse 162 m² of their land; initially offering ₱243,000 (₱1,500/m²), then withdrawing compensation on grounds of a public-land easement.
- The Spouses Regulto protested by letter (May 30, 2011), filed a complaint (October 8, 2011) for just compensation and injunctive relief before RTC Naga City, Branch 62.
- Trial Court Proceedings
- Petitioners moved to dismiss (August 5, 2011) citing lack of cause of action and failure to exhaust administrative remedies; RTC denied the motion (October 17, 2011).
- RTC issued writ of possession and ordered deposit of ₱36,450 for the 162 m² (January 2, 2012), sustained on reconsideration (January 27, 2012).
- RTC ruled on May 24, 2012 that petitioners must pay ₱243,000 as just compensation for the traversed area and found waiver of the C.A. No. 141 easement reservation.
Issues:
- Whether lands originally granted by free patent remain subject to the C.A. No. 141 right-of-way easement after issuance of TCT and subsequent subdivision, or whether the government waived the easement by inaction.
- Whether Section 8 (“Expropriation”) or Section 5 (“Quit Claim”) of the IRR of R.A. No. 8974 governs the mode of acquisition for lands under C.A. No. 141.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)