De Castro Homesite v. Leachon
REITERATIONFacts
The Antecedents: The underlying dispute involves criminal charges filed by De Castro Homesite, Inc. against various individuals for alleged violations of Presidential Decree No. 772, commonly known as the “Anti-Squatting Law.” These charges stemmed from the occupation of residential lands owned by De Castro Homesite, Inc. in Cubao, Quezon City. The core issue in both consolidated cases revolves around the constitutionality and continued applicability of Presidential Decree No. 772 in light of the 1987 Constitution and subsequent legislation. Procedural History: In G.R. No. 124856, De Castro Homesite, Inc. filed complaints leading to Informations for violation of PD 772. The Metropolitan Trial Court (MeTC) denied the private respondents’ Motion to Quash, which argued the unconstitutionality of the decree. Subsequently, the Regional Trial Court (RTC), in a petition for certiorari, declared PD 772 unconstitutional and enjoined the MeTC from proceeding. In G.R. No. 127971, similar charges were filed, and the MeTC denied the petitioners’ Motion to Quash, stating PD 772 had not been declared unconstitutional by the Supreme Court. The RTC denied their petition for certiorari, and the Court of Appeals affirmed this denial, holding that PD 772 had not been declared unconstitutional nor repealed by Republic Act No. 7279. The Petition: Both consolidated petitions before the Supreme Court primarily challenge the constitutionality of Presidential Decree No. 772. G.R. No. 124856 is a Petition for Certiorari challenging the RTC's order declaring PD 772 unconstitutional. G.R. No. 127971 is a Petition for Review on Certiorari assailing the Court of Appeals' decision affirming the RTC's denial of the Motion to Quash, arguing that PD 772 remained valid. The Supreme Court, however, noted that PD 772 had been expressly repealed by Republic Act No. 8368, which mandated the dismissal of all pending cases under PD 772, rendering the petitions moot.
Issue(s)
Whether Presidential Decree No. 772 is constitutional, considering the enactment of Republic Act No. 8368. Whether the RTC in G.R. No. 124856 erred in declaring PD 772 unconstitutional and enjoining the MeTC proceedings, especially in light of RA 8368. Whether the RTC and Court of Appeals in G.R. No. 127971 erred in denying the Motion to Quash and the subsequent petitions, upholding the MeTC's denial, given the repeal of PD 772 by RA 8368.
Ruling
The consolidated petitions are DISMISSED. The criminal cases subject of these petitions are likewise DISMISSED.
Ratio Decidendi
On the Constitutionality and Legality of Presidential Decree No. 772: The Supreme Court noted that the core issue in both consolidated cases revolved around the constitutionality of PD 772. Congress addressed this with the enactment of Republic Act No. 8368, the "Anti-Squatting Law Repeal Act of 1997," which took effect on December 27, 1997. This law expressly repealed PD 772. Section 3 of RA 8368 explicitly mandated that "all pending cases under the provisions of Presidential Decree No. 772 shall be dismissed upon the effectivity of this Act." This legislative act rendered further disquisition on the constitutionality of PD 772 superfluous. On the RTC's declaration in G.R. No. 124856: The declaration by a co-equal branch of government (Congress) effectively mooted the legal questions presented before the Court regarding the constitutionality of PD 772. The express repeal by RA 8368 superseded considerations of whether PD 772 was unconstitutional under the 1987 Constitution or impliedly repealed by RA 7279. The dismissal of the cases was a direct consequence of this legislative repeal and the mandate to dismiss all pending cases. On the RTC and Court of Appeals' denial in G.R. No. 127971: Given the express repeal of PD 772 by RA 8368 and the mandate to dismiss all pending cases under PD 772, any error in the lower courts' denial of the Motion to Quash and subsequent petitions is rendered moot. The legislative action of repealing PD 772 effectively resolves the legal issues raised in these petitions.
Main Doctrine
Presidential Decree No. 772, the "Anti-Squatting Law," was expressly repealed by Republic Act No. 8368, the "Anti-Squatting Law Repeal Act of 1997," which mandated the dismissal of all pending cases filed under PD 772. Consequently, the issue of PD 772's constitutionality became moot.