Air Transportation Office v. Gopuco
REITERATIONFacts
The Antecedents: Respondent Apolonio Gopuco, Jr. was the owner of Lot No. 72, a 995-square meter parcel of land near the Lahug Airport in Cebu City. In 1952, the Civil Aeronautics Administration (CAA) filed an expropriation case for Lot No. 72 and neighboring properties for airport expansion. In 1961, the Court of First Instance (CFI) declared the expropriation justified, ordered the payment of a balance of ₱1,990.00 to Gopuco with legal interest, and directed the transfer of title to the Republic of the Philippines upon payment. The judgment became final, and absolute title to Lot No. 72 was transferred to the Republic in 1962. In 1989, Lahug Airport was ordered closed by President Corazon C. Aquino. In 1990, Gopuco wrote to the Bureau of Air Transportation seeking the return of his lot, offering to return the payment received, but his letter was ignored. In 1992, ownership of Lot No. 72 was transferred to the Mactan-Cebu International Airport Authority (MCIAA) under Republic Act No. 6958. Procedural History: On August 6, 1992, Gopuco filed a complaint for recovery of ownership of Lot No. 72 against the Air Transportation Office and the Province of Cebu, alleging that the closure and abandonment of Lahug Airport caused the property to revert to him. He also claimed an assurance from the CAA that the lots would be resold to them if no longer used for the airport, though he later admitted no compromise agreement was entered into for his lot. The Regional Trial Court (RTC) dismissed Gopuco's complaint and ordered him to pay exemplary damages, litigation expenses, and costs to MCIAA. Gopuco appealed to the Court of Appeals, which reversed the RTC decision, ordered MCIAA to reconvey Lot No. 72 to Gopuco upon payment of its reasonable price, and deleted the award of damages and costs. MCIAA's motion for reconsideration was denied. The Petition: Petitioners Air Transportation Office (ATO) and Mactan-Cebu International Airport Authority (MCIAA) filed a petition for review, questioning the Court of Appeals' ruling that Gopuco had the right to reclaim ownership of the lot and its deletion of the award for litigation expenses and costs.
Issue(s)
Whether the Court of Appeals erred in holding that respondent has the right to reclaim ownership over the subject expropriated lot based on the import of the December 29, 1961 Decision in Civil Case No. 1881. Whether the Court of Appeals erred in deleting the award of litigation expenses and costs in favor of petitioners.
Ruling
The petition is GRANTED. The Decision of the Court of Appeals is REVERSED and SET ASIDE. The Decision of the RTC is REINSTATED with the modification that the award of exemplary damages, litigation expenses and costs are DELETED.
Ratio Decidendi
On the right to reclaim ownership: The Court held that when land is acquired for public use in fee simple, unconditionally, either by eminent domain or by purchase, 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, or any reversion to the former owner. The judgment of expropriation in Civil Case No. R-1881 vested absolute and unconditional title in the government, as it granted title in fee simple. This ruling is consistent with the principle laid down in Fery v. Municipality of Cabanatuan and reiterated in Mactan-Cebu International Airport Authority v. Court of Appeals. The Court clarified that the expropriation was not conditioned on the continued operation of the Lahug Airport, and there was no explicit statement in the judgment that the land would revert to its former owners upon abandonment of the public use. The respondent's claim of an "implied contract" for repurchase was unsubstantiated and not recognized in the context of eminent domain. Furthermore, the respondent could not invoke compromise agreements entered into by other lot owners as he was not a party to them. The Court distinguished the present case from Heirs of Timoteo Moreno v. Mactan-Cebu International Airport Authority, where a constructive trust was found due to preponderant proof of a right of repurchase, which was absent in Gopuco's case. On the award of litigation expenses and costs: The Court deleted the award of exemplary damages, litigation expenses, and costs because the petitioners failed to present any proof that the case was clearly unfounded or filed for purposes of harassment, or that the respondent acted in gross and evident bad faith. It is not sound public policy to set a premium upon the right to litigate when such right is exercised in good faith, as in the present case.
Main Doctrine
When land is acquired for public use in fee simple, unconditionally, either by the exercise of eminent domain or by purchase, 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, or any reversion to the former owner.