Bulacan v. San Diego Inc.
REITERATIONFacts
The Antecedents: The Province of Bulacan, through Resolution No. 787, authorized the acquisition of Hacienda Esguerra, owned by B. E. San Diego, Inc., for subdivision and resale to tenants and landless residents, pursuant to Republic Acts Nos. 267 and 498. A complaint for expropriation was filed. Procedural History: Several lots were excluded from the complaint upon showing that they were already sold by B. E. San Diego, Inc. to the Central Cooperative Exchange, Inc. prior to the filing of the action. An amended complaint was filed for the remaining portion. Defendant B. E. San Diego, Inc. moved to dismiss, arguing the property was not a landed estate, the purpose was not public, and portions had already been sold. The lower court dismissed the complaint, citing several cases. The Petition: The Province of Bulacan appealed, arguing that the case should be determined based on the ruling in Rural Progress Administration vs. Clemente Reyes, not the cases cited by the lower court.
Issue(s)
Whether the land sought to be expropriated, with an area of about 26 hectares and with several portions already sold, falls within the purview of Republic Acts Nos. 267 and 498. Whether the purpose of expropriation, to subdivide and resell to tenants and landless residents, constitutes a public purpose justifying expropriation under the Constitution.
Ruling
The appealed order of dismissal is affirmed. The Province of Bulacan has no cause of action for the expropriation of the remaining 26 hectares of Hacienda Esguerra.
Ratio Decidendi
On whether the land falls within the purview of Republic Acts Nos. 267 and 498: The Court held that the land sought to be expropriated, with an area of approximately 26 hectares and with several portions already sold to private parties, does not fall within the purview of Republic Acts Nos. 267 and 498. The Court reiterated its ruling in Province of Rizal vs. B. E. San Diego, Inc. (G.R. No. L-10802, January 23, 1959), which was based on the principle that expropriation is permissible only for landed estates with extensive areas. Once such an estate is broken up into parcels of reasonable areas, these resulting parcels are no longer subject to further expropriation under Article XIII, Section 4 of the Constitution. The Court emphasized that the ruling in Rural Progress Administration vs. Clemente Reyes was abandoned in favor of the doctrine in Guido vs. Rural Progress Administration. On whether the purpose constitutes a public purpose: The Court affirmed the lower court's conclusion that the purpose of enabling tenants of a piece of land of reasonable area to own portions thereof, even if they and their ancestors had cultivated it for many years, is not a valid reason or justification under the Constitution to deprive the owner of his property by means of expropriation. The Constitution protects landowners against indiscriminate and unwarranted expropriation. To justify expropriation, it must be for a public purpose and public benefit. The Court found that the property in question was no longer a landed estate and that the purpose of subdividing and reselling to tenants did not meet the constitutional requirement for public use, especially after portions had already been sold to third parties.
Main Doctrine
The government may expropriate only landed estates with extensive areas. Once a landed estate is broken up into parcels of reasonable areas, either through voluntary sales or expropriation, the resulting parcels are no longer subject to further expropriation under Article XIII, Section 4 of the Constitution. Mere tenancy troubles do not justify expropriation, which must be for a public purpose and public benefit.