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MACTAN-CEBU INTERNATIONAL AIRPORT AUTHORITY v. HEIRS OF MARCELINA L. SERO

FACTS:

The respondents filed a complaint against the petitioner and other defendants for recovery of ownership and declaration of nullity of TCTs. They claimed that the subject properties originally belonged to their predecessor but were fraudulently reconstituted and sold. The properties were later acquired by CAA through expropriation for the Lahug Airport's expansion. After MCIAA was created, the functions were transferred to them. MCIAA denied the allegations and sought the dismissal of the complaint. The RTC dismissed the complaint, but the Court of Appeals reversed the decision, stating that the complaint alleged sufficient cause of action and should be resolved in trial. MCIAA filed a petition for review, arguing that the respondents had no cause of action, and their claims were barred by laches and prescription. The respondents argued that the properties should be returned since the purpose of expropriation was no longer valid due to the closure of Lahug Airport. The Court of Appeals failed to consider a previous Supreme Court decision on the issue of reconveyance.

ISSUES:

  1. Whether the respondents have a cause of action against the petitioner.

  2. Whether the respondents' action is barred by prescription and laches.

RULING:

  1. On the cause of action: The Supreme Court held that the respondents did not have a cause of action against the petitioner. The properties in question were acquired by the State in fee simple, which means that the original owners retained no rights to the land, regardless of whether the purpose for the expropriation had ended or was abandoned. Thus, the first element of a cause of action—plaintiff's legal right—was not present.

  2. On prescription and laches: The Supreme Court held that even if the respondents had a right to the subject properties, such right was barred by prescription and laches. An action for reconveyance based on fraud must be filed within ten (10) years from the issuance of the title. The respondents' action was filed thirty-eight (38) years after the trial court granted the expropriation, thus it was clearly beyond the ten-year prescriptive period. Additionally, the respondents were also barred by laches due to their inaction over the long period.

PRINCIPLES:

  1. Elements of Cause of Action: The legal right of the plaintiff, the correlative obligation of the defendant, and the act or omission of the defendant in violation of said legal right.

  2. Judicial Notice: Courts must take judicial notice of statutes and decisions material and relevant to cases before them.

  3. Acquisition of Property by the State: When land is acquired for public use in fee simple, unconditionally, 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 reversion to the former owner.

  4. Prescription in Reconveyance: An action for reconveyance on the grounds of fraud must be filed within ten (10) years from the issuance of the title.

  5. Laches: Negligence or omission to assert a right within a reasonable time, under circumstances prejudicial to the adverse party, operates as a bar in a court of equity.