96. White Plains Association v.

CA

FACTS: Respondent Quezon City Development & Financing Corporation (QCDFC) was the owner and developer
of White Plains Subdivision in Quezon City prior to the sale of the lots therein to the residents of the
subdivision who comprised the petitioner White Plains Association, Inc. (Association). The disputed area of the
land was set aside and dedicated to the proposed Highway 38 of Quezon City. As subdivision owner and
developer, respondent QCDFC represented to the lot buyers that there would be a thoroughfare known as
Katipunan Avenue and that the width of the land allotted to said road was 38 meters. Of the 38 meters,
respondent QCDFC developed only 20 meters. The undeveloped strip of land, 18 meters in width, of the
proposed Katipunan Avenue has been and still is the subject of court litigation.

As early as April 14, 1970, QCDFC filed a petition with the then Court of First Instance of Rizal for the
conversion into residential lots of this undeveloped strip of land. The controversy reached this Court. On
November 14, 1985, this Court en banc dismissed the petition. In the said decision this Court ruled that “Road
Lot 1 is withdrawn from the commerce of man and should be developed for the use of the general public.”

ISSUE: Who owns the Road Lot 1?

RULING: QCDFC. Even assuming that in spite of its dimensions, the 18-meter wide and 1 kilometer long
undeveloped area may be used for public purpose other than C-5, QCDFC contends in this petition that just
compensation will have to be paid for it. As stated by QCDFC, this is because the area has never been donated;
title remains with the developer; the purpose for which the reservation was made can no longer be
implemented; and under the law, even indisputably, subdivision streets belong to the owner until donated to
the government or until expropriated upon payment of just compensation.