People v. Vigonte
REITERATIONFacts
The Antecedents: Private respondents were charged with violation of Presidential Decree No. 772 (penalizing squatting) for allegedly occupying and building a house on the land of Felix Yara in Barrio Bagongbayan, Puerto Princesa City, and refusing to vacate despite demands. Procedural History: The private respondents filed a motion to quash the information, alleging that the facts charged do not constitute an offense. The City Court of Puerto Princesa City, presided over by respondent Judge, dismissed the information, opining that P.D. No. 772 penalizes squatting only in urban communities and not just any community, and the information failed to allege that Barrio Bagongbayan is an urban community. The Petition: The prosecution moved for reconsideration, which was denied. The People of the Philippines, through the Solicitor General, filed a petition for review on certiorari, assailing the dismissal order and the denial of the motion for reconsideration.
Issue(s)
Whether Presidential Decree No. 772 penalizes squatting in both urban and rural communities. Whether the facts charged in the information constitute an offense under P.D. No. 772.
Ruling
The petition is dismissed, and the orders of the court a quo dated May 17 and May 31, 1976, are affirmed. The Supreme Court held that the facts charged do not constitute an offense.
Ratio Decidendi
On whether Presidential Decree No. 772 penalizes squatting in both urban and rural communities: The Supreme Court reiterated its rulings in People vs. Echaves and Bernardo vs. People, holding that Presidential Decree No. 772 applies only to urban communities. The preamble of P.D. No. 772 explicitly states its purpose is to address squatting in "urban communities" and that "many persons or entities found to have been unlawfully occupying public and private lands belong to the affluent class." This indicates a specific intent to curb a problem prevalent in urban settings, particularly concerning illegal constructions by individuals who are not necessarily indigent. The decree was not intended to cover all forms of land occupation in any community, but rather a specific problem in urban areas. On whether the facts charged in the information constitute an offense under P.D. No. 772: Since P.D. No. 772 is applicable only to urban communities, and the information filed in the case at bar did not allege that Barrio Bagongbayan, Puerto Princesa City, where the alleged squatting occurred, is an urban community, the facts charged do not constitute an offense. The respondent Judge, therefore, did not commit any reversible error in dismissing the information on this ground. The absence of an allegation specifying the nature of the community as "urban" is fatal to the charge under the established interpretation of P.D. No. 772.
Main Doctrine
Presidential Decree No. 772, penalizing squatting, applies only to urban communities and not to rural areas, as indicated by its preamble and subsequent Supreme Court interpretations.