Kabiling v. National Housing Authority
REITERATIONFacts
The Antecedents: Petitioners assailed the constitutionality of P.D. No. 1808, alleging deprivation of property without due process and just compensation, violation of equal protection, and impairment of contracts. They also claimed their properties were not proper subjects of expropriation. Procedural History: The original petition was filed on July 14, 1981. Respondents filed their comments, which were considered as answers. Memoranda were submitted. The Court denied petitioners' urgent petition for a temporary restraining order. An Amended Petition was filed on May 21, 1986, adding the ground of non-publication of P.D. No. 1808. The Court admitted the Amended Petition and required respondents to comment. Respondent NHA confirmed P.D. No. 1808 was published and provided a status report on the project, detailing development, investments, compensation deposits, and lot titling. The Solicitor General maintained the Republic's position for dismissal. The Court dismissed the Amended Petition on July 22, 1986. Petitioners filed a motion for reconsideration. The Petition: Petitioners sought reconsideration of the resolution dismissing their amended petition, reiterating their grounds and praying for a decision on the merits.
Issue(s)
Whether P.D. No. 1808 is constitutional. Whether P.D. No. 1808 deprives petitioners of property without due process of law. Whether P.D. No. 1808 violates the equal protection clause. Whether P.D. No. 1808 impairs the obligation of contracts. Whether petitioners' properties are proper subjects of expropriation. Whether petitioners are entitled to just compensation.
Ruling
The Court denied the motion for reconsideration and maintained its resolution dismissing the amended petition for lack of merit. P.D. No. 1808 was upheld as a valid exercise of police power.
Ratio Decidendi
On the constitutionality of P.D. No. 1808: The Court held that P.D. No. 1808 is a valid exercise of the State's police power. The decree's objective, to resolve the land tenure problem in the Agno-Leveriza area and allow the implementation of comprehensive development plans for a depressed community under the Zonal Improvement Program, provides sufficient justification for the exercise of this power. Police power is an inherent, plenary, and essential power of the State, aimed at ensuring communal peace, safety, good order, and welfare, and individual rights cannot unreasonably obstruct such salutary measures. On deprivation of property without due process of law: Petitioners' claim of deprivation of property without due process is without merit. The exercise of police power, as demonstrated by P.D. No. 1808, is a legitimate governmental function that can affect property rights when done in the interest of public health, safety, morals, and general welfare. The decree itself provides for just compensation, thus mitigating any claim of arbitrary deprivation. On violation of equal protection: The Court found no merit in the contention that P.D. No. 1808 violates the equal protection clause. The decree targets a specific depressed area with a unique land tenure problem for a legitimate public purpose, which is a valid classification. The Zonal Improvement Program aims to address specific societal needs, and differential treatment based on such needs does not inherently violate equal protection. On impairment of the obligation of contracts: The objection that P.D. No. 1808 impairs the obligation of contracts is also without merit. The constitutional guaranty against impairment of obligations of contract is not absolute and is subordinate to the State's exercise of its police power for the public good. The decree's objectives of slum improvement and resettlement serve the general welfare, justifying any incidental impact on contractual obligations. On properties being subjects of expropriation: Petitioners' claim that their properties are not proper subjects of expropriation is implicitly rejected by the Court's affirmation of P.D. No. 1808. On just compensation: Furthermore, the decree provides for just compensation to lot owners who have fully paid their obligations. For those who have not yet received compensation, the Court, applying the ruling in Export Processing Zone Authority vs. Hon. Ceferino Dulay, held that they are entitled to a judicial determination of the just compensation for their lots.
Main Doctrine
Presidential Decree No. 1808, which directs the cancellation of awards, contracts of sale, and titles of lots within the Agno-Leveriza Tenant Association Subdivision and their reconveyance to the government upon payment of just compensation, and orders the expropriation of adjacent vacant lots for upgrading under the Zonal Improvement Program, is a valid exercise of the State's police power. The constitutional guaranty against impairment of obligations of contract and the right to due process are subject to the exercise of police power for the public welfare. Owners who have fully paid their obligations are entitled to just compensation, while those who have not are entitled to a judicial determination of such compensation.