Case Digest (G.R. No. L-10280) Core Legal Reasoning
Facts:
The case involves the Republic of the Philippines (Civil Aeronautics Administration) as the petitioner, against respondents Ramon Yu, Teofista Villamala, Lourdes Yu, and Yu Se Peng. The decision under review originates from the Court of Appeals and was dated December 2, 2002, concerning the remand of a dismissed complaint regarding the reversion of an expropriated property. The background is rooted in previous decisions, notably Valdehueza v. Republic (1966), where the court ruled that certain petitioners were not entitled to recover possession of Lot No. 939 in Lahug, Cebu City but were entitled only to its fair market value. Subsequent to this, in Yu v. Republic (1986), the Court of Appeals annulled the sale of the same lot to the respondents, concluding they were not purchasers in good faith; this decision became final.
Following these matters, on October 1, 1992, the respondents initiated a complaint for the reversion of the expropriated property. The Republic opposed this
Case Digest (G.R. No. L-10280) Expanded Legal Reasoning
Facts:
- Antecedents and earlier final judgments
- Lot No. 939 in Lahug, Cebu City, was expropriated for the Lahug Airport by the Republic of the Philippines (through the Civil Aeronautics Administration).
- In Valdehueza v. Republic (L-21032, May 19, 1966, 17 SCRA 107), the Supreme Court affirmed the judgment of expropriation and ruled that the erstwhile owners (Francisca Valdehueza, et al.) could not recover possession of Lot No. 939; they were only entitled to demand its fair market value.
- After the expropriation judgment, Valdehueza, et al. sold Lot No. 939 to Ramon Yu, et al. (herein respondents). In Yu v. Republic (CA-G.R. CV No. 01223, October 30, 1986), the Court of Appeals annulled said sale, held that respondents were not purchasers in good faith, and declared that the land belonged to the Republic. No appeal was taken; the judgment became final and executory.
- The reversion suit and lower court rulings
- On October 1, 1992, respondents filed a complaint in the RTC of Cebu (Civil Case No. CEB-12968) for reversion of the expropriated property, alleging the government had abandoned the Lahug Airport and had returned other nearby expropriated properties, thus giving rise to a right of reversion.
- The Republic (CAA) denied respondents’ right to reacquire title or possession, and moved to dismiss on grounds of res judicata, lack of cause of action, and forum shopping.
- On November 16, 1995, the RTC, Branch 11, Cebu City, dismissed the complaint on the ground of res judicata (bar by prior final judgment).
- Proceedings in the Court of Appeals and the present petition
- On appeal, the Court of Appeals (CA-G.R. CV No. 53712, Decision dated December 2, 2002) reversed the RTC, ruled that res judicata did not apply, and remanded the case for trial on the merits.
- The Republic filed a petition for review on certiorari. The petition was assigned to the Supreme Court Third Division (G.R. No. 157557). Justice Quisumbing penned the Decision promulgated on March 10, 2006.
Issues:
- Res judicata
- Whether the reversion action is barred by res judicata in light of (a) Valdehueza v. Republic (1966) affirming expropriation, and (b) Yu v. Republic (CA, 1986) annulling the sale to respondents and declaring the land owned by the Republic.
- Whether the applicable mode of res judicata is “bar by prior judgment” or “conclusiveness of judgment,” and whether the requisites are satisfied.
- Reversion and standing
- Whether the alleged abandonment of Lahug Airport and return of other expropriated parcels created a new cause of action for reversion in favor of respondents.
- Whether respondents, whose source of title (the sale from Valdehueza, et al.) was annulled with finality, have any legal right or personality to seek reversion of Lot No. 939.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)