Facts: This case revolves around Lot 941, a piece of land with an area of 13,766 square meters located in Lahug, Cebu City, adjacent to the Lahug Airport, and registered under the Mactan-Cebu International Airport Authority (MCIAA) following its creation through Republic Act No. 6958 in 1990. Initially, during the liberation period, the Lahug Airport was occupied by the United States Army and was later turned over to the Philippine Government in 1947. Subsequently, it was managed by several government agencies until the creation of MCIAA. In April 1952, the Republic of the Philippines, represented by the then Civil Aeronautics Administration (CAA), initiated expropriation proceedings for several parcels of land including Lot 941, for the expansion and improvement of Lahug Airport. Virginia Chiongbian acquired Lot 941 in June 1953, but the government had begun using the land since November 16, 1947. A judgment in favor of the Republic was rendered in 1961, paying Chiongbian P34,415.00 for the lot.
In July 1995, Chiongbian filed a complaint for reconveyance of Lot 941 with the RTC of Cebu, claiming an assurance was made by the National Airports Corporation to reconvey the land should it cease to be used as an airport. Following the transfer of airport activities to Mactan International Airport in 1991, Chiongbian asserted that the Lahug Airport’s closure satisfied the condition for reconveyance. The RTC and subsequently the Court of Appeals ruled in favor of Chiongbian. MCIAA appealed to the Supreme Court, challenging the lower courts’ decisions and the admissibility of parol evidence to prove the alleged repurchase agreement.
Issues:
1. Whether parol evidence was admissible to establish the repurchase agreement claimed by Chiongbian.
2. Whether the Court of Appeals erred in applying the decision in Limbaco vs. Court of Appeals to the case at bar.
3. Whether the judgment in CA G.R. No. 33045 should benefit Chiongbian even if she was not a party in the appealed case.
4. Whether Chiongbian has a right to repurchase Lot No. 941 under the same terms and conditions as other landowners.
Court’s Decision:
The Supreme Court granted MCIAA’s petition, reversing and setting aside the decision of the Court of Appeals. It ruled that the terms of the expropriation judgment granted the Republic of the Philippines a fee simple title to Lot No. 941, without any condition for reconveyance or repurchase rights for Chiongbian. The Court held that parol evidence to prove the existence of a repurchase agreement or a compromise settlement was inadmissible, as it would contravene the final and executory judgment of the expropriation proceedings. Moreover, Chiongbian’s testimonies were deemed hearsay and inadmissible since they were not based on her personal knowledge but on her lawyer’s assurances. Consequently, Chiongbian had no cause of action for the reconveyance of Lot No. 941 against MCIAA.
Doctrine:
The Supreme Court reiterated that when land is acquired for public use in fee simple, unconditionally, through expropriation proceedings, the former owner retains no rights in the land, and the public use may be abandoned or the land may be devoted to a different use without any impairment of the estate or title acquired.
Class Notes:
– In expropriation cases, the nature of the title acquired depends on the decree of expropriation. If the decree grants a fee simple title, the expropriator holds absolute property rights.
– Parol evidence rule prohibits the use of verbal or unwritten evidence to contradict, vary, add to, or subtract from the terms of a written agreement.
– Statute of Frauds requires certain contracts, including those for the sale of real property, to be in writing to be enforceable.
– Hearsay evidence, which is based not on the witness’s own testimony but on the statement of another, is generally inadmissible except for certain exceptions.
Historical Background:
The case illustrates the legal complexities surrounding expropriated lands and the rights of former owners vis-à-vis the changed circumstances of land use by the government. It underscores the procedural and substantive legal principles governing expropriation, repurchase rights, and the importance of definitive terms in the judgment of expropriation.
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