Case Summary (G.R. No. 9408)
Procedural History
- 1962 CFI (R-7208): Upholds heirs’ ownership, orders deed of sale to Republic upon payment of ₱16,248.40 + interest.
- 1966 SC (L-21032): Affirms CFI; recognizes landowners’ right only to demand payment, not possession.
- 1992 Lim v. Republic (RTC CEB-12701): Lim obtains judgment declaring him absolute owner of Lot 932.
- 2003 CA (CA-G.R. CV 72915): Affirms RTC, citing over 50-year delay violates just-compensation requirement and constitutes a cloud on Lim’s title.
- 2004 SC (G.R. No. 161656): Denies review and reconsideration; Republic’s subsequent motions disallowed under Rule 52.
Issue
Whether the Republic retained ownership of Lot 932 despite its failure to pay just compensation within a reasonable time and whether Lim, as a foreclosing mortgagee, is entitled to quiet title and possession.
Ruling and Legal Analysis
- Constitution demands payment of just compensation “within a reasonable time” as an element of due process.
- Title to expropriated property passes only upon full payment of just compensation; mere entry for public use does not vest title.
- Decades-long non-payment frustrates constitutional guarantee, converts the government’s status from lawful occupant to wrongful possessor.
- Jurisprudence (e.g., Provincial Government of Sorsogon v. Vda. De Villaroya) condemns bureaucratic delay and oppressive exercise of eminent domain.
- The five-year execution period under Rule 39, Section 6, RCP, encourages prompt payment; beyond this, owner may recover possession.
- Lim’s mortgage and foreclosure occurred while heirs retained ownership; his acquisition is valid and protected under Civil Code, Article 2127.
- Bad faith issue is immaterial because the Republic never perfected title; annotation merely
Case Syllabus (G.R. No. 9408)
Facts of the Case
- On September 5, 1938, the Republic instituted expropriation of Lots 932 (25,137 sqm, TCT No. 14921) and 939 (13,164 sqm, TCT No. 12560) in Lahug, Cebu City, for military reservation.
- Republic deposited ₱9,500.00 with PNB per CFI order (October 19, 1938) and took possession of both lots.
- May 14, 1940: CFI ordered payment of ₱4,062.10 as just compensation to the Denzons; appeal dismissed March 11, 1948; judgment entered April 5, 1948.
- 1950: Heir Jose Galeos claimed rentals; National Airports Corporation denied knowledge.
- 1961: Armed Forces expressed willingness to pay appraised value; no payment ensued.
- September 20, 1961: Successors Francisca Galeos-Valdehueza and Josefina Galeos-Panerio filed recovery of possession with damages (Civil Case No. R-7208); new titles (TCT Nos. 23934, 23935) issued November 9, 1961, annotated “subject to the priority of the National Airports Corporation…upon previous payment of a reasonable market value.”
- July 31, 1962: CFI held successors as owners, adjusted compensation to ₱16,248.40 plus 6% interest from April 5, 1948; ordered deed of sale upon payment.
- May 19, 1966: SC (L-21032) affirmed CFI—successors remained owners; only entitled to fair market value; possession not restored.
- 1964: Lot 932 mortgaged to Vicente Lim; foreclosure in 1976; new title (TCT No. 63894) issued to Lim.
- August 20, 1992: Lim filed quieting of title (RTC CEB-12701) against Republic and officials; amended complaint added Republic.
- May 4, 2001: RTC (Branch 10) declared Lim absolute owner of Lot 932; dismissed monetary claims.
- September 18, 2003: CA (CA-G.R. CV No. 72915) affirmed RTC—Republic’s 50-year nonpayment was oppressive; Lim’s title cloud removed.
- March 1 and May 17, 2004: SC denied petition for review and motions for reconsideration for lack of reversible error.
- June 29, 2005: SC en banc resolved ownership, nonpayment, and possession issues on merits.
Procedural History
- Expropriation commenced before CFI of Cebu (Civil Case No. 781, 1938).
- Appeal from 1940 CF