Case Summary (G.R. No. 162288)
Factual Background
Milagros Urgello was the owner of Lot No. 913-E of the Banilad Estate in Cebu City, which was subdivided into smaller parcels, including Lot No. 913-E-3. In the 1950s, the then Civil Aeronautics Administration (CAA) initiated a process to expropriate Lot No. 913-E-3 for the expansion of Lahug Airport, leading to a compromise agreement wherein the government agreed to repurchase the lot, reverting ownership back to Urgello if it was no longer used for airport purposes.
Expropriation and Lease Agreements
By 1966, operations were transferred to the newly developed Mactan Airport, and the Lahug Airport ceased to function. In 1983, the Bureau of Air Transportation (renamed from CAA) entered a lease agreement with the DPWH, including Lot No. 913-E-3. Respondent Urgello filed various legal complaints to secure ownership of her properties after the encroachment caused by the construction activities of the government agencies.
Reconveyance and Legal Proceedings
In January 1989, the Regional Trial Court (RTC) ruled in favor of Urgello, affirming her right to reconveyance of Lot No. 913-E-3 after she tendered the agreed purchase price. A subsequent memorandum and a compromise agreement in 1990 incorporated terms regarding the payment for other lots and obligations to demolish illegally constructed fences.
Failure to Comply with Agreements
Despite Urgello's compliance with the agreements, the government agencies failed to execute the demolition as mandated and did not reconvey the disputed lots. Hurting the respondent’s claims for damages, the RTC subsequently ruled in favor of Urgello regarding her claims for ownership and rental payments due to the government's unlawful occupation of her properties.
Solidarity of Obligation
The RTC rendered a decision in 1999 holding all three defendants—DPWH, MCIAA, and ATO—solidarily liable to reconvey Lot No. 913-E-3, return other specified lots, and pay corresponding rentals for their extended unlawful occupation. The trial court deemed that, under Republic Act No. 6958, MCIAA assumably emerged as the legal custodian of the Lahug Airport properties, thereby inheriting associated liabilities.
Appeal and Court Findings
On appeal, the Court of Appeals affirmed the lower court's decision regarding the solidary liability of the petitioners. It addressed the claims concerning the assumption of obligations by MCIAA as ATO's successor post-creation under RA 6958. The decisions emphas
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Case Overview
- Respondent Milagros Urgello owned Lot No. 913-E of the Banilad Estate in Cebu City, covered by Transfer Certificate of Title No. 10873.
- Lot No. 913-E was subdivided into four parcels: 913-E-1, 913-E-2, 913-E-3, and 913-E-4.
- In the 1950s, the Civil Aeronautics Administration (CAA) initiated expropriation proceedings for Lot No. 913-E-3 for the expansion of Lahug Airport, culminating in a compromise agreement in 1964.
Compromise Agreement and Conditions
- The CAA agreed to purchase Lot No. 913-E-3 for P3,105.00, with a resolutory condition: if not used as an airport, ownership would revert to Urgello upon reimbursement of the purchase price.
- Urgello executed a Conditional Deed of Sale, which was annotated on her title.
Changes in Airport Operations
- By April 27, 1966, operations shifted to Mactan Airport, leading to the cessation of operations at Lahug Airport by Philippine Airlines, Filipinas Airways, and Air Manila.
- In 1983, the Bureau of Air Transportation (BAT) and the Ministry of Public Works and Highways (MPWH) entered into a Memorandum of Agreement to lease Lot No. 913-E-3 for 25 years.
Legal Actions Initiated by Respondent
- Urgello filed a Complaint for Injunction with Damages against BAT and G.M. Tiongco Construction on June 5, 1983, due to fencing on her property.
- On July 8, 1985, she requested reconveyance of Lot No. 913-E-3 and tendere