Case Summary (G.R. No. 197743)
Invalidity of the Deed of Donation
The purported 1954 donation was never registered or annotated on TCT No. 671 and bore a defective acknowledgment:
- Absent signatures of the donors’ spouses and the City’s mayor at notarization.
- Mayor Imperial’s signature was four days post-notarization.
Accordingly, the instrument lacked public character and was void.
Inapplicability of Laches as a Bar
Although the City argued laches, the court held that delay alone does not suffice. Petitioners’ predecessors actively pursued their rights by demanding purchase or reconveyance; family inheritance disputes delayed discovery of full title; formal demand occurred only after estate administration in 1997. The City’s own decades of title inactivity reinforced petitioners’ entitlement.
Taking and Available Remedies
The court deemed respondent a trespasser ab initio when it occupied and improved petitioners’ land without expropriation, invoking the doctrine of Manila Railroad Co. upon which government instrumentalities stand on no higher footing than private intruders. Where return of property is no longer feasible due to permanent government structures, the sole remedy is payment of just compensation.
Just Compensation and Interest
Just compensation is the fair market value of the land at the time of taking (August 16, 1954). To secure full and equitable indemnity, courts apply:
• Inflation adjustment of 1954 value to present-day equivalent.
• Legal interest on the inflation-adjusted figure at prevailing rates:
– 6% per annum on forbearance of money from Aug 16, 1954 to June 30, 2013;
– 12% per annum from July 1, 2013 until date of payment (per BSP Circulars).
This methodology compensates petitioners for both loss of property and opportunity cost of withheld funds.
Exemplary Damages and Attorney’s Fees
Respondent’s illegal, decades-long occupation without due process mandates exemplary damages of P1,000,
...continue readingCase Syllabus (G.R. No. 197743)
Facts
- July 3, 1954: City Heights Subdivision (CHS) offers to donate 5-hectare parcel (part of TCT No. 671) to City of Naga for City Hall site
- July 30, 1954: CHS amends offer to donate full 5-hectare parcel, detailing 2 ha for City Hall, 2 ha for plaza, 1 ha for market; offer signed by registered owners Macario Mariano and Jose Gimenez and their spouses
- August 11 & 16, 1954: City’s Municipal Board adopts Resolution No. 89; Deed of Donation executed by Mayor Monico Imperial, Mariano, and Gimenez
- Post-1954: City enters, improves, and uses property as government center; other agencies build offices on site
- Condition for donation (award of construction contract to CHS) never complied; City later proposes to purchase land instead
- 1959 & 1968: Mariano’s successors demand return or purchase; no action taken
- 1971–1997: Inheritance and adoption disputes delay discovery of the land by heirs; administrator appointed March 11, 1997
- September 2003: Administrator demands City vacate and pay damages
- February 12, 2004: Heirs file Complaint for Unlawful Detainer against City of Naga, seeking recovery of possession, monthly rentals, and attorney’s fees
Procedural History
- February 2005: MTC, Branch I, Naga City dismisses complaint for lack of jurisdiction
- June 2005: RTC, Branch 26, Naga City reverses MTC; orders City to vacate land, surrender possession, and pay P2.5 million/month as rent
- July 2011: CA reinstates MTC dismissal; finds ownership dispute beyond unlawful detainer
- March 12 & July 23, 2018: SC First Division reverses CA, voids Deed of Donation, finds City in bad faith; orders vacation, surrender of possession, half-rentals from Nov 30, 2003, exemplary damages reduced to P75,000 attorney’s fees
- 2018–2022: City’s first motions for reconsideration denied; Second Motion for Reconsideration (2nd MR)