The Supreme Court ruled that the respondents did not have the legal capacity to sue to annul the title over a disputed property. According to the facts, Cebu City had expropriated property owned by Galileo Figuracion in 1948 to use as a street, but later reconveyed the unused portion to Figuracion's successor, Isagani Figuracion. Spouses Cresenciano and Libi attempted to annul this title, claiming right of way, but abandoned their original cause of action. As they had no real interest in the property, the respondents had no legal standing to file suit. The Court also affirmed that Cebu City was authorized to reconvey public land no longer needed based on powers delegated
The Supreme Court ruled that the respondents did not have the legal capacity to sue to annul the title over a disputed property. According to the facts, Cebu City had expropriated property owned by Galileo Figuracion in 1948 to use as a street, but later reconveyed the unused portion to Figuracion's successor, Isagani Figuracion. Spouses Cresenciano and Libi attempted to annul this title, claiming right of way, but abandoned their original cause of action. As they had no real interest in the property, the respondents had no legal standing to file suit. The Court also affirmed that Cebu City was authorized to reconvey public land no longer needed based on powers delegated
The Supreme Court ruled that the respondents did not have the legal capacity to sue to annul the title over a disputed property. According to the facts, Cebu City had expropriated property owned by Galileo Figuracion in 1948 to use as a street, but later reconveyed the unused portion to Figuracion's successor, Isagani Figuracion. Spouses Cresenciano and Libi attempted to annul this title, claiming right of way, but abandoned their original cause of action. As they had no real interest in the property, the respondents had no legal standing to file suit. The Court also affirmed that Cebu City was authorized to reconvey public land no longer needed based on powers delegated
The Supreme Court ruled that the respondents did not have the legal capacity to sue to annul the title over a disputed property. According to the facts, Cebu City had expropriated property owned by Galileo Figuracion in 1948 to use as a street, but later reconveyed the unused portion to Figuracion's successor, Isagani Figuracion. Spouses Cresenciano and Libi attempted to annul this title, claiming right of way, but abandoned their original cause of action. As they had no real interest in the property, the respondents had no legal standing to file suit. The Court also affirmed that Cebu City was authorized to reconvey public land no longer needed based on powers delegated
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Figuracion v Libi (2007)
DOCTRINE: A city can validly reconvey a portion of its street that has been closed or withdrawn from public use where Congress has specifically delegated to such political subdivision, through its charter, the authority to regulate its streets. Such property withdrawn from public servitude to be used or conveyed for any purpose for which other property belonging to the city may be lawfully used or conveyed.
FACTS: Galileo Figuracion was the owner of a lot situated in Cebu City. In 1948, the Cebu City government expropriated such lot turning such into a portion of N. Escario St. Cebu City paid and was issued a TCT. Cebu City Sangguniang Panglungsod approved the reconveyance to Isagani Figuracion, Galileo's successor-in-interest, of an unused portion of the aforesaid lot; a TCT was issued in Isagani’s favor. It appears that Spouses Cresenciano & Libi had been using the subject lot and refused to vacate despite demand. Isagani filed a complaint for unlawful detainer against them. Spouses Cresenciano & Libi filed against the petitioners a complaint for easements, praying that they be granted a right of way over the subject lot. They amended their complaints twice to implied Cebu City, and shifted the cause of action from establishment of right of way to annulment of TCT 122309. RTC in CEB-21193 ruled that the resolutions assailed, Deed of Sale, Amended Deed of Sale, and TCT 122309 as null and void.
ISSUE: W/N the CA erred in not ruling that respondents do not have the legal capacity to sue - YES
HELD:
The Court ruled in the affirmative stating that it is readily apparent that respondents were not the real-parties-in-interest to institute Civil Case No. CEB-21193 for annulment of TCT No. 122309. Spouses Cresenciano & Libi abandoned their original cause of action as such respondents having no real interest in the subject lot under their Second Amended Complaint, they have no legal personality to file the action for reversion of public land. In fine, the RTC acted without jurisdiction when it entertained the Second Amended Complaint of respondents even when the latter was not a real party- in-interest. As a general rule, local roads used for public service are considered public property under the absolute control of Congress; hence, local governments have no authority to control or regulate their use. However, under Section 10, Chapter II of the Local Government Code, Congress delegated to political subdivisions some control of local roads. In the present case, there exists no doubt that Cebu City repudiated its right to use the subject lot for other public purpose; and instead, recognized the right of the former owner or his successor-in- interest to repurchase the same.
