City of Manila v. Prieto
REITERATIONFacts
The Antecedents: The City of Manila (petitioner) enacted Ordinance No. 8070 authorizing the City Mayor to acquire parcels of land belonging to respondents for its Land-For-The-Landless Program. Petitioner initially attempted a negotiated sale, offering ₱2,000.00 per square meter, which respondents rejected. Petitioner then filed a complaint for expropriation, asserting its authority and seeking a writ of possession, having deposited ₱4,812,920.00 representing over 100% of the assessed value. The Regional Trial Court (RTC) initially denied the writ, requiring a deposit of 15% of the fair market value as mandated by the Local Government Code (LGC). Upon compliance with the additional deposit of ₱852,519.00 (partially by petitioner and partially by prospective beneficiaries), the RTC issued a Writ of Possession. Procedural History: The RTC granted the complaint for expropriation, finding that all requisites for eminent domain were met, including public purpose (Land-for-the-Landless and on-site development programs), prior definite offers, and justification for acquiring private lands despite being last in priority under R.A. No. 7279. The RTC's order of expropriation was issued, and motions for reconsideration were denied. The Court of Appeals (CA) reversed and set aside the RTC's order, finding that petitioner failed to justify non-compliance with R.A. No. 7279 regarding the order of priorities for land acquisition, the definition of on-site development, the exhaustion of other modes of acquisition, and the qualification of beneficiaries as "underprivileged and homeless." The CA's resolution denying petitioner's motion for reconsideration led to the present petition. The Petition: Petitioner seeks review of the CA's decision, asserting its power to expropriate and its compliance with constitutional and legal provisions. The core issue is whether the CA erred in finding that petitioner failed to prove compliance with pertinent laws in exercising its power of eminent domain.
Issue(s)
Whether the Court of Appeals erred in finding that the petitioner failed to prove that it complied with pertinent laws in the exercise of its power of eminent domain. Whether the petitioner sufficiently justified the deviation from the order of priorities in land acquisition under Section 9 of R.A. No. 7279. Whether the petitioner sufficiently proved that the intended beneficiaries of the socialized housing program are "underprivileged and homeless" as contemplated under R.A. No. 7279. Whether the petitioner exhausted other modes of acquisition before resorting to expropriation as required by Section 10 of R.A. No. 7279.
Ruling
The petition is denied. The Decision of the Court of Appeals, which reversed and set aside the Order of the Regional Trial Court, is affirmed.
Ratio Decidendi
On the failure to prove compliance with pertinent laws in the exercise of eminent domain: The Supreme Court reiterated that the exercise of eminent domain, a delegated power to local government units, must strictly comply with constitutional and statutory limitations. The Court found that the petitioner failed to discharge its burden of proof. The RTC's facile approach in concluding that all requisites were met was found insufficient. The Court emphasized that courts must judiciously scrutinize the exercise of this power due to its drastic effect on the right to private property. Bare allegations and unsupported generalizations, as presented by the petitioner, do not suffice to justify deviations from mandatory provisions. On the justification for deviating from the order of priorities under R.A. No. 7279: The Court found no evidence that petitioner complied with Section 9 of R.A. No. 7279, which outlines priorities in land acquisition for socialized housing. Petitioner's claim that on-site development was the most practicable and advantageous was based on bare allegations without supporting studies or evidence. There was no showing that lands in higher priority categories (government-owned, alienable public domain, etc.) were first considered before resorting to privately-owned lands. Furthermore, petitioner failed to prove that the subject properties qualified as blighted areas suitable for on-site development as defined by the law. On the qualification of beneficiaries: The Court agreed with the CA that petitioner failed to present evidence that the intended beneficiaries were the "underprivileged and homeless" as required by Section 8 of R.A. No. 7279. The testimony of a witness indicated that the beneficiaries had the means to purchase properties and included professionals, contradicting the classification. The substantial amount contributed by these beneficiaries for the court-ordered deposit further supported the finding that they were not "underprivileged and homeless." On the exhaustion of other modes of acquisition: The Court affirmed the CA's finding that petitioner failed to establish that other modes of acquisition under Section 10 of R.A. No. 7279 were exhausted. Section 10 mandates that expropriation should only be resorted to when other modes have been exhausted. The Court noted that after respondents rejected the initial offer, petitioner immediately filed the expropriation suit without renegotiating. This failure to exhaust reasonable efforts to acquire the land by agreement warrants the dismissal of the complaint, as a valid and definite offer requires a reasonable offer made in good faith, not merely a pro forma one.
Main Doctrine
A local government unit's exercise of the delegated power of eminent domain must strictly comply with the conditions and restrictions set forth in the Constitution and pertinent laws, including the order of priority in land acquisition and the exhaustion of other modes of acquisition before resorting to expropriation. Bare allegations and unsupported generalizations do not suffice to justify non-compliance.