Nobleza v. Romero Valdellon
REITERATIONFacts
The Antecedents: Simon Nobleza sold a parcel of land, measuring 1,129 square meters, to the National Power Corporation (NPC) in 1941 for P1,470. The land was intended for the construction of NPC's transmission lines. Procedural History: On December 6, 1979, Nobleza filed a complaint against the NPC and the Presiding Judge of the Court of First Instance of Rizal, Pasig Branch XXII. He sought to compel the NPC to resell the land to him through a negotiated sale, rather than through public bidding as contemplated by NPC's Board Resolution No. 142, series of 1979. The NPC filed a motion to dismiss, arguing lack of cause of action. The lower court dismissed the complaint, finding no violation of Nobleza's rights. Nobleza appealed this dismissal to the Supreme Court. The Petition: Nobleza appealed the dismissal of his complaint, contending that his action was based on equitable principles. He sought to purchase the land through a negotiated sale, arguing that it was no longer being used for a public purpose.
Issue(s)
Whether the National Power Corporation (NPC) can be compelled to resell a parcel of land to its original seller through a negotiated sale, instead of public bidding. Whether the landowner has a right to repurchase the land when it is no longer used for public purposes.
Ruling
The Supreme Court affirmed the lower court's order of dismissal. No costs were awarded.
Ratio Decidendi
On Whether the National Power Corporation (NPC) can be compelled to resell a parcel of land to its original seller through a negotiated sale, instead of public bidding: The Court held that the disposition of government property is governed by specific laws, including the Government Auditing Code (Presidential Decree No. 1445). Section 79 of this decree mandates that unserviceable government property should be disposed of by public bidding. A private sale is only permissible if public bidding fails. The Commission on Audit, in a letter dated June 4, 1980, reminded the NPC of this provision. Although the NPC initially passed a resolution authorizing the resale of the land to Nobleza, this resolution was later revoked by NPC Resolution No. 199, series of 1980, after the NPC President apprised the National Power Board that the land was still being utilized as a right-of-way for an existing transmission line, which was scheduled for replacement. The Court found no error in the lower court's dismissal of the complaint, as there was no showing that the NPC had violated any right of Nobleza. On Whether the landowner has a right to repurchase the land when it is no longer used for public purposes: The Court did not directly rule on whether the landowner has an inherent right to repurchase the land if it ceases to be used for public purposes. Instead, the resolution focused on the procedural requirements for the disposition of government property. The case was dismissed on the ground that the NPC had not violated any right of Nobleza by adhering to the legal procedures for property disposal. The fact that the land was still being utilized as a right-of-way, as indicated by the NPC President's letter, further supported the NPC's position. Furthermore, Nobleza's counsel failed to submit a comment on the auditor's opinion and the revocation of the NPC's resolution, despite being asked to do so by the Supreme Court.
Main Doctrine
The National Power Corporation (NPC), a government-owned and controlled corporation, is bound by the provisions of the Government Auditing Code regarding the disposition of unserviceable government property. Presidential Decree No. 1445 mandates that such property should be disposed of through public bidding, and a private sale is only permissible if public bidding fails. The Court affirmed the dismissal of the landowner's complaint to compel a negotiated sale, as the NPC's initial resolution to resell the land was revoked after considering the legal requirements for property disposition and the land's continued use.