National Housing Authority v. Reyes
REITERATIONFacts
The Antecedents: The National Housing Authority (NHA) filed a complaint for expropriation of a parcel of land owned by Quirino Austria, pursuant to Presidential Decree No. 757, for the expansion of the Dasmariñas Resettlement Project. The NHA later secured an order for a writ of possession. Quirino Austria filed a Motion to Withdraw Deposit of P6,600.00, which was the property's value assessed for taxation purposes, deposited by the NHA under Presidential Decree No. 42. Procedural History: The NHA opposed the withdrawal, citing Section 92 of Presidential Decree No. 464, which states that just compensation shall not exceed the lower of the market value declared by the owner or the assessor's determination. The NHA argued that the owner's declaration of P1,400.00, being lower than the assessor's assessment, should be the just compensation. The respondent Judge issued an order allowing the withdrawal, which the NHA contended was contrary to law. The NHA filed a Motion for Reconsideration, citing Presidential Decree No. 1224, which also provides for the lower of the owner's declared value or the assessor's determination as the basis for just compensation. The motion was denied. The Petition: The NHA filed a petition for certiorari and mandamus with preliminary injunction, seeking to nullify the respondent Judge's order. The Supreme Court issued a temporary restraining order and required respondents to comment. The private respondents argued that while the judge might not have followed the decrees, the matter was still subject to his judicial discretion. No question was raised as to the validity of the Presidential Decrees.
Issue(s)
Whether certiorari lies against the respondent Judge for failure to comply with the provisions of the Presidential Decrees regarding the amount to be paid by the petitioner to entitle it to a writ of possession in an expropriation proceeding, when the validity of said Decrees was not questioned. Whether the respondent Judge committed grave abuse of discretion in issuing an order contrary to the letter and spirit of Presidential Decree No. 464 and Presidential Decree No. 1224 concerning the determination of just compensation in expropriation proceedings.
Ruling
The Supreme Court granted the writ of certiorari, nullified and set aside the order of the respondent Judge dated July 13, 1978, made permanent the temporary restraining order issued by the Court, and remanded the case to the lower court for further action conformably to law and the opinion.
Ratio Decidendi
On the issue of certiorari and compliance with Presidential Decrees: The Court held that certiorari lies because no question was raised as to the validity of the Presidential Decrees governing the determination of just compensation in expropriation proceedings. The Court emphasized the presumption of validity of legislative or executive acts, citing Angara v. Electoral Commission and Ermita-Malate Hotel & Motel Operators Association, Inc. v. City Mayor of Manila. Since both public and private respondents failed to challenge the validity of the decrees in their comments, the Court had no choice but to apply the law as it clearly and unequivocally spoke. The decrees, having spoken in no uncertain language, called for obedience. The Court reiterated that it is not the judiciary's role to pass upon the wisdom, justice, or expediency of legislation, but rather to apply the law as enacted, especially when its validity is not put in issue. On the issue of grave abuse of discretion and determination of just compensation: The Court found that the respondent Judge's order was contrary to the clear mandate of Presidential Decree No. 464 and Presidential Decree No. 1224. These decrees explicitly provided that the basis for payment of just compensation in expropriation proceedings shall not exceed the lower of the market value declared by the owner or the market value determined by the assessor. The NHA's submission that the owner's declared value of P1,400.00, being lower than the assessor's assessment, should be the just compensation was consistent with these decrees. The respondent Judge's order allowing the withdrawal of P6,600.00, which was the assessor's valuation, thus contravened the statutory provisions. The Court noted that the purpose of these decrees was to promote social justice and prevent the practice of under-declaring properties for taxation while inflating their price when acquired by the government. The Court also highlighted the NHA's mandate under Presidential Decree No. 757 to address the housing problem, which necessitates efficient and rational acquisition of land, and the constitutional obligation of the State to provide adequate housing.
Main Doctrine
In certiorari proceedings challenging an order related to expropriation, where no question is raised as to the validity of the Presidential Decrees governing the matter, the Court must grant the remedy sought and apply the law as it clearly and unequivocally speaks.