National Housing Authority v. Allarde
REITERATIONFacts
The Antecedents: Lots 836 and 839, registered in the name of the Republic of the Philippines and part of the Tala Estate in Kalookan City, were reserved by Proclamation No. 843 on April 26, 1971, for housing programs of the National Housing Authority (NHA). Private respondent Rufino Mateo claimed to have lived on and cultivated a portion of these lots since 1928 and 1959, respectively. In 1983, NHA notified the Mateo spouses of the scheduled development of the Tala Estate. In 1989, Rufino Mateo filed a petition with the Department of Agrarian Reform for the award of the lots under the Comprehensive Agrarian Reform Program (CARP). In January 1992, NHA bulldozed the ricefields of the Mateo spouses. Procedural History: On March 18, 1992, the Mateo spouses filed a complaint for damages with a prayer for a writ of preliminary injunction before the Regional Trial Court (RTC) of Kalookan City, seeking to enjoin NHA from further bulldozing and construction. They argued that the lots were agricultural lands covered by CARP. NHA countered that the lots were reserved for housing and resettlement and were not agricultural lands under R.A. No. 6657. On April 8, 1992, the RTC granted the writ of preliminary injunction, finding the lots to be agricultural and covered by CARP, and aiming to maintain the status quo. NHA's motion for reconsideration, arguing that the injunction violated P.D. No. 1818 which prohibits injunctions against government infrastructure projects, was denied on August 4, 1992. The Petition: The NHA filed a Petition for Certiorari with the Supreme Court, assailing the RTC's orders granting and denying reconsideration of the preliminary injunction, alleging grave abuse of discretion amounting to lack of jurisdiction.
Issue(s)
Whether the respondent Judge gravely abused his discretion amounting to lack of jurisdiction in issuing the writ of preliminary injunction. Whether the Comprehensive Agrarian Reform Law (CARL) covers government lands reserved for specific public purposes prior to the effectivity of said law. Whether housing and resettlement projects are "infrastructure projects" within the contemplation of P.D. No. 1818.
Ruling
The petition is granted. The Orders dated April 8, 1992, and August 4, 1992, of the Regional Trial Court of Kalookan City are set aside, and the writ of preliminary injunction issued is dissolved.
Ratio Decidendi
On the issue of whether the respondent Judge gravely abused his discretion amounting to lack of jurisdiction in issuing the writ of preliminary injunction: The Supreme Court held that the respondent Judge committed grave abuse of discretion. The Court found that the RTC's orders were bereft of sustainable basis because the lands in question were not covered by the Comprehensive Agrarian Reform Law (CARL) and the injunction violated Presidential Decree No. 1818. The Court emphasized that for a preliminary injunction to issue, there must be a clear showing of a right to be protected, which was absent in this case. The disruption of essential government projects necessitated the Court's intervention through certiorari. On whether the Comprehensive Agrarian Reform Law (CARL) covers government lands reserved for specific public purposes prior to the effectivity of said law: The Court ruled in the negative. Citing Natalia Realty, Inc. vs. Department of Agrarian Reform, the Court reiterated that lands reserved for or converted to non-agricultural uses by government agencies other than the Department of Agrarian Reform, prior to CARL's effectivity, are not considered agricultural lands and are thus outside its ambit. Presidential Proclamation No. 843, issued on April 26, 1971, reserved the Tala Estate for housing programs of the NHA, categorizing it as not devoted to agricultural activity as defined by Section 3(c) of R.A. No. 6657. Therefore, the lots were outside the coverage of CARL. On whether housing and resettlement projects are "infrastructure projects" within the contemplation of P.D. No. 1818: The Court held in the affirmative. Presidential Decree No. 1818 prohibits courts from issuing injunctive writs against the implementation of government infrastructure projects. The Court, applying the principle of ejusdem generis, found that the housing and resettlement projects undertaken by the NHA, as described in Proclamation No. 843, constitute "infrastructure projects." These projects involve construction, improvement, and rehabilitation that form part of the government's capital investment, aligning with the constitutional mandate for urban land reform and housing. Consequently, the RTC's injunction against these projects was a violation of P.D. No. 1818.
Main Doctrine
Government lands reserved for specific public purposes prior to the effectivity of the Comprehensive Agrarian Reform Law (CARL) are not covered by CARL, and housing and resettlement projects are considered infrastructure projects within the contemplation of Presidential Decree No. 1818, prohibiting courts from issuing injunctive writs against their implementation.