Case Digest (G.R. No. 147511) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1977, the National Housing Authority (NHA) initiated expropriation proceedings (Civil Case Nos. T.G.-392, T.G.-396, T.G.-417) before the Court of First Instance of Cavite to acquire Lot Nos. 6450, 6448-E, 6198-A, and 6199 in Dasmariñas, Cavite, owned by petitioners—heirs and successors of the Zaballero family. The stated purpose was to expand the Dasmariñas Resettlement Project for squatters relocated from Metro Manila. In 1987, this Court affirmed the expropriation and the obligation to pay just compensation, which became final on November 26, 1987. On February 24, 1989, the expropriation court issued an Alias Writ of Execution directing the Register of Deeds to transfer titles to NHA and ordering NHA to segregate attorney’s fees, pay legal expenses under PD 1529, coordinate capital gains tax payments with the petitioners, and complete relocation.Alleging non-compliance with the relocation and payment directives, petitioners filed on April 28, 1992, a forfeiture of right
Case Digest (G.R. No. 147511) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Expropriation proceedings
- In 1977, the National Housing Authority (NHA) filed separate expropriation complaints before the Court of First Instance of Cavite against petitioners’ sugarcane lands (Lot Nos. 6450, 6448-E, 6198-A, 6199) for the expansion of the Dasmariñas Resettlement Project to relocate Metro Manila squatters.
- The trial court ordered expropriation and payment of just compensation; this was affirmed by the Supreme Court on October 29, 1987 (final November 26, 1987).
- Alias Writ of Execution
- On February 24, 1989, the expropriation court issued an Alias Writ of Execution ordering the Register of Deeds to transfer titles in NHA’s name and directing NHA to pay adjudicated compensation, attorney’s fees (₱322,123.05), and registration expenses; defendants were to pay capital gains tax.
- Complaint for forfeiture of rights
- On April 28, 1992, petitioners filed before RTC Quezon City a complaint for forfeiture, alleging NHA’s failure to relocate squatters and to pay just compensation.
- NHA answered that it had paid substantial amounts but faced issues on capital gains tax, registration fees, and attorneys’ fees.
- Ocular inspection and trial court decision
- Ocular inspections (1994) showed partial occupation by relocatees on Lot 6198-A, but other lots were occupied by third parties or remained vacant.
- On September 29, 1995, the RTC dismissed the forfeiture complaint, holding that:
- NHA pursued the public purpose via a low-cost housing contract;
- No reversion condition was in the expropriation judgment;
- Compensation payment is independent of petitioners’ tax obligations;
- Compensation is based on value at taking.
- Court of Appeals and Supreme Court appeal
- On September 29, 2000, the Court of Appeals affirmed the RTC decision and denied petitioners’ motion for reconsideration (March 13, 2001).
- Petitioners elevated the case to the Supreme Court, asserting (a) lack of reversion clause precludes forfeiture; (b) non-payment is ground for forfeiture; (c) failure to use property for intended purpose warrants forfeiture.
Issues:
- Whether NHA’s alleged abandonment of the stated public purpose and non-payment of just compensation and petitioners’ capital gains tax justify forfeiture of NHA’s rights under the expropriation judgment.
- Whether the absence of an express reversion condition in the expropriation decree precludes reversion of title.
- Whether petitioners may recover possession of the expropriated lands or are limited to compensation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)