Case Summary (G.R. No. 240895)
Petition and Background
The petition seeks to reverse and set aside the Court of Appeals' ruling dated December 14, 2017, and its resolution dated July 23, 2018, which favored the private respondents. The Court of Appeals found that the Regional Trial Court (RTC) had erred by dismissing the Complaint in Civil Case No. CEB-21557, and thus ordered the RTC to determine just compensation for the taking of Lot No. 7245, which the DPWH claimed had reverted to the government as part of a national road.
Case Proceedings
The conflict originated in two civil cases filed regarding the property. Civil Case No. CEB-21557 was initiated by Romeo Rallos, who sought recovery of possession, partitioning, and damages. In contrast, Civil Case No. CEB-25079 was filed by the DPWH seeking reversion of the property title to the State. The RTC combined both cases for resolution.
RTC's Finding
In its Judgment dated October 30, 2009, the RTC dismissed both complaints. The court reasoned that the private respondents failed to prove their lineage deriving from Numeriana Rallos, the last will's legatee, and also highlighted the lack of evidence for rightful inheritance. Consequently, it found no grounds to confirm private respondents’ ownership claim over the property.
Appeal Decision by the CA
The Court of Appeals dismissed DPWH's appeal concerning the dismissal of Civil Case No. CEB-25079 and granted Romeo Rallos' appeal in part, indicating that the RTC should determine just compensation owed to Romeo for the property expropriated without due compensation, aligning its ruling with the precedent in Secretary of the DPWH v. Spouses Tecson.
Issues Raised by the Petitioner
In its petition, the Republic contended that the respondents did not possess valid ownership over Lot No. 7245 and sought the cancellation of the derivative titles that resulted from the flawed reconstitution proceedings. The argument stressed the property’s designation as part of the public domain and the alleged irregularities surrounding private respondents' title.
Arguments from the Private Respondents
Private respondents countered the DPWH's claims, maintaining the Court of Appeals' reasoning that no sufficient evidence was presented suggesting that the subject property was indeed part of the national road and reiterated their rightful claims based on TCT No. 145498.
The Supreme Court's Ruling
The Supreme Court ruled that the DPWH's appeal should be upheld. It found that the private respondents were unable to demonstrate valid ownership rights or entitlement to just compensation for Lot No. 7245. The Court emphasized the necessity for the State to prove the property’s status as public land and the وجود fraud in
...continue readingCase Syllabus (G.R. No. 240895)
Introduction
- This case involves a petition for review on certiorari by the Republic of the Philippines, represented by the Department of Public Works and Highways (DPWH), seeking to set aside the decision of the Court of Appeals (CA) dated December 14, 2017, and the resolution dated July 23, 2018.
- The CA had ruled in favor of private respondent Romeo Rallos, remanding the case for the determination of just compensation for the taking of a specific parcel of land (Lot No. 7245).
Antecedents
- The subject property is a 439-square-meter parcel of land in Cebu City, originally registered under Original Certificate of Title (OCT) No. RO-3105 (O-1930).
- The title was judicially reconstituted, and subsequently, Transfer Certificate of Title (TCT) No. 145498 was issued to the respondents.
- The DPWH filed a complaint for reversion and cancellation of the title, alleging the property had always been part of the national road (V. Rama Avenue).
- Private respondent Romeo Rallos filed a separate complaint for recovery of possession, partition, and damages, claiming to be a successor-in-interest of the original owner.
Civil Case No. CEB-21557
- Romeo Rallos alleged that he and other respondents were heirs of Numeriana Rallos, a previous owner who bequeathed the property to her nephew, Francisco Rallos.
- The DPWH countered that the property was part of a national road and claimed laches on the part of Romeo for the delay in asserting his rights.
- The RTC dismissed the complaint, stating that private respondents failed to establish their claims of heirship and