Case Digest (G.R. No. 179334) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Secretary of the Department of Public Works and Highways and District Engineer Celestino R. Contreras v. Spouses Heracleo and Ramona Tecson (G.R. No. 179334, July 1, 2013), respondents Heracleo and Ramona Tecson, co-owners of a 7,268-sqm lot in San Pablo, Malolos, Bulacan (TCT No. T-43006), asserted that in 1940 the Department of Public Works and Highways (DPWH) and its District Engineer, Celestino Contreras, took permanent possession of their land for the construction of the MacArthur Highway without expropriation proceedings or compensation. In December 1994 they demanded payment of the fair market value; the DPWH offered ₱0.70/sqm per a 1950 Provincial Appraisal Committee (PAC) resolution. When no agreement was reached, the Tecsons filed in March 1995 a complaint for recovery of possession with damages in the RTC of Malolos (Civil Case No. 208-M-95), claiming the lot’s value at ₱2,543,800. The RTC granted petitioners’ motion to dismiss on state-immunity grounds, but the CA Case Digest (G.R. No. 179334) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Spouses Heracleo and Ramona Tecson (respondents) co‐owned a 7,268 sqm lot in San Pablo, Malolos, Bulacan (TCT No. T-43006).
- The Department of Public Works and Highways (DPWH) and District Engineer Celestino R. Contreras (petitioners) took possession of the lot in 1940 for MacArthur Highway construction without respondents’ consent and without expropriation proceedings or payment of compensation.
- Procedural History
- December 15, 1994 – Respondents demand current fair market compensation; petitioner Contreras offers ₱0.70/sqm per a 1950 PAC resolution.
- March 17, 1995 – Respondents file an accion reivindicatoria with damages against DPWH/Contreras.
- June 28, 1995 – RTC (Branch 80, Malolos) dismisses complaint for lack of jurisdiction, invoking state immunity.
- July 31, 2007 – CA (G.R. CV No. 77997) reverses RTC, orders remand to determine just compensation.
- March 22, 2002 – On remand, RTC refers case to Provincial Appraisal Committee (PAC), which recommends ₱1,500/sqm; RTC adopts recommendation.
- July 31, 2007 – CA affirms RTC decision but adds 6% interest p.a. from March 17, 1995 until full payment.
- July 1, 2013 – SC resolves Rule 45 petition: modifies CA decision to award ₱0.70/sqm with 6% interest p.a. from the 1940 taking until full payment.
Issues:
- Whether respondents’ suit is barred by prescription or laches.
- Whether state immunity bars an action for just compensation.
- Whether just compensation should be based on the land’s value at time of taking (1940) or at time of payment (current fair market value).
- Whether respondents’ ownership and title to the property are valid.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)