Case Summary (G.R. No. 139495)
Petitioner
Mactan-Cebu International Airport Authority (MCIAA)
Respondent
Virginia Chiongbian (with the Court of Appeals as nominal co-respondent)
Key Dates
• April 16, 1952 – Expropriation filed by Civil Aeronautics Administration in CFI Cebu.
• June 1953 – Chiongbian’s purchase of Lot 941 from Antonina Faborada.
• December 29, 1961 – Final judgment in expropriation awarding Chiongbian ₱34,415 with interest; title transferred to Republic.
• 1990 – Republic Act No. 6958 creates MCIAA; assets of Lahug Airport, including Lot 941, vest in MCIAA.
• May 8, 1992 – Title to Lot 941 registered in MCIAA’s name.
• July 24, 1995 – Chiongbian files reconveyance suit (RTC Cebu Branch 9, CEB-17650).
• June 3, 1997 – RTC renders judgment ordering MCIAA to reconvey Lot 941 upon reimbursement of ₱34,415.
• November 27, 2000 – Supreme Court decision reversing CA and RTC.
Applicable Law
• 1987 Philippine Constitution, Art. III, Sec. 9 (eminent domain authority of the State).
• Republic Act No. 6958 (creation of MCIAA).
• Civil Code Art. 1403 (Statute of Frauds requirement for contracts on real property).
• 1997 Rules of Civil Procedure (verification and non-forum shopping requirements).
• Evidentiary rules on hearsay and admissibility of parol evidence.
• Jurisprudence: Fery v. Municipality of Cabanatuan (42 Phil. 28 [1921]); Noble v. City of Manila (67 Phil. 1 [1938]); Limbaco v. CA (263 SCRA 736 [1996]).
Factual Background
Lot 941, a 13,766 sqm parcel adjoining Lahug Airport in Cebu City, was originally privately owned. During and after World War II, U.S. forces occupied it; in 1947 it reverted to the Philippine Government, passing through the Surplus Property Commission, Bureau of Aeronautics, National Airports Corporation, and Civil Aeronautics Administration. In 1952 the CAA expropriated Lot 941 for airport expansion. Though Chiongbian had acquired the same land in 1953, she received full compensation by final 1961 judgment and the title was duly transferred to the Republic. No condition of reversion or repurchase was stated in that judgment.
Procedural History
Chiongbian did not appeal the 1961 expropriation judgment; she withdrew her award and accepted payment. After Lahug Airport’s closure in 1991 and the full shift of operations to Mactan International Airport, she sued MCIAA in 1995 for reconveyance “upon assurance” that, if the airport use ceased, she could repurchase the land at her original compensation price. The RTC granted her reconveyance claim; the Court of Appeals affirmed. MCIAA elevated the case by petition for certiorari under Rule 45.
Issue on Reconveyance
Whether the abandonment of the public use for which Lot 941 was expropriated entitles the original owner to reacquire it, when the expropriation decree granted absolute fee simple title without conditional reversion or reserved repurchase rights.
Supreme Court’s Analysis on Character of Title and Abandonment
Under Fery v. Municipality of Cabanatuan, the right of former owners to reacquire expropriated land depends on whether the taking granted fee simple title unconditionally or included a reversionary condition. The 1961 expropriation decree conveyed fee simple title to the Republic of the Philippines, fixed just compensation, and directed transfer of title without mentioning any reversion or repurchase condition. Thus MCIAA, as successor to the Republic, holds absolute title. Non-use or abandonment of airport operations does not revive any right of Chiongbian.
Evidentiary Considerations: Parol Evidence and Statute of Frauds
Chiongbian sought to prove a collateral “repurchase agreement” by parol testimony of herself, a family acquaintance,
Case Syllabus (G.R. No. 139495)
Facts of the Case
- Subject property: Lot 941, 13,766 sqm in Lahug, Cebu City, originally under TCT No. 120366 in MCIAA’s name.
- World War II: U.S. Army occupied Lahug Airport; 1947 turnover to Philippine Government via Surplus Property Commission.
- Successive agencies: Bureau of Aeronautics → National Airports Corporation → Civil Aeronautics Administration (CAA).
- April 16, 1952: Republic of the Philippines (via CAA) filed expropriation Civil Case No. R-1881 to expand Lahug Airport, including Lot 941.
- June 1953: Virginia Chiongbian purchased Lot 941 from Antonina Faborada for ₱8,000; TCT No. 9919 issued in her name.
- December 29, 1961: Expropriation judgment awarded Chiongbian ₱34,415 plus legal interest from November 16, 1947; she did not appeal.
- Title transfers: post-judgment TCT No. 27696 to Republic; 1992 TCT No. 120366 to MCIAA (created by RA 6958 in 1990).
- Airport closure: Lahug Airport ceased operations end-1991 upon opening of Mactan International Airport.
Procedural History
- July 24, 1995: Chiongbian filed reconveyance complaint (RTC Cebu Branch 9, Civil Case No. CEB-17650), alleging repurchase right once airport was abandoned.
- June 3, 1997: RTC granted her reconveyance upon refund of expropriation price; ordered title transfer from MCIAA back to Chiongbian.
- CA Appeal: MCIAA appealed; Court of Appeals affirmed RTC decision and denied MCIAA’s motion for reconsideration.
- Supreme Court: MCIAA filed Petition for Review on Certiorari under Rule 45 of the Rules of Court.
Issues Presented
- Whether MCIAA erred in excluding respondent’s oral evidence under the Statute of Frauds.
- Whether the ruling in Limbaco v. CA (contract of sale case) is applicable.
- Whether the modified judgment in CA-G.R. No. 33045‐R benefits Chiongbian, who was not a party.
- Whether Chiongbian’s repurchase price should be fixed at ₱34,415 (same as other landowners) or determined at current market value.
- Respondent’s contention that the petition should be dismissed for lack of valid certification against forum shopp