Manapat v. Court of Appeals
REITERATIONFacts
The Antecedents: The underlying dispute concerns parcels of land within the Grace Park Subdivision in Caloocan City, originally owned by the Roman Catholic Archbishop of Manila (RCAM) and/or Philippine Realty Corporation (PRC). In the 1960s, occupants of the land, who had been allowed to occupy it with the understanding they might vacate for a planned school, organized and petitioned the government to acquire the property for resale to them. Initial government efforts to acquire the land were unsuccessful due to cost. RCAM then proceeded to subdivide and sell lots to the public, including petitioners Fermin Manapat and Domingo Lim, and respondents Maximo Loberanes, Eladio Quimque, Cesario Vega, Juanito Santos, Alejandro Oracion, and Gonzalo Mercado. A significant development occurred in 1977 when Presidential Decree No. 1072 appropriated funds for the expropriation of these lots by the National Housing Authority (NHA) for development under the Zonal Improvement Program (ZIP) and resale to residents. Procedural History: The NHA initiated numerous expropriation proceedings against the subdivided lots. The Regional Trial Court (RTC) initially dismissed most of these cases, ordering condemnation only in two. Upon NHA's motion for reconsideration, the RTC amended its decisions in several cases, ordering condemnation and fixing just compensation at P180.00 per square meter. NHA appealed the dismissals and the compensation rulings to the Court of Appeals (CA), which consolidated these appeals. The CA, in a May 27, 1993 decision, reversed the dismissals, affirmed the condemnations, but annulled the trial court's compensation rates, remanding the cases for determination of just compensation. Subsequent motions for reconsideration led to a March 2, 1994 CA resolution modifying its earlier decision, exempting certain lots from expropriation, and a July 25, 1994 resolution denying further reconsideration. Separately, the CA reversed an RTC ruling in another expropriation case on June 28, 1994. These CA decisions and resolutions form the basis of the petitions before the Supreme Court. The Petition: Three consolidated petitions for review on certiorari under Rule 45 are before the Court. G.R. No. 110478, filed by Fermin Manapat, argues that expropriating his lot is incongruous as he is a beneficiary of the program and questions the necessity of the taking and the CA's application of legislative power. G.R. Nos. 116491-503, filed by the NHA, challenges the CA's March 2, 1994 and July 25, 1994 resolutions, contending that the CA erred in retroactively applying Republic Act No. 7279 (Urban Development and Housing Act of 1992) to exempt small lots from expropriation, as the expropriation cases were initiated prior to the law's enactment. G.R. No. 116176, filed by Domingo Lim, questions the NHA's authority to re-group smaller lots and argues there was no genuine necessity for the expropriation of his lots. The core issue across all petitions is whether the NHA may validly expropriate the subject parcels of land.
Issue(s)
Whether the NHA may validly expropriate the parcels of land subject of these cases. Whether the Court of Appeals erred in retroactively applying R.A. No. 7279 to exempt small property owners from expropriation. Whether the determination of necessity for expropriation is a justiciable or political question. Whether the concept of 'public use' in eminent domain includes socialized housing and urban development. Whether the size of the lots or the number of beneficiaries affects the public use character of expropriation.
Ruling
The Supreme Court affirmed the Court of Appeals' May 27, 1993 Decision in CA-G.R. CV No. 10200-10212 and the June 28, 1994 Decision in CA-G.R. CV No. 27159. It reversed and set aside the March 2, 1994 and July 25, 1994 Resolutions in CA-G.R. CV Nos. 10200-10212. The Court ruled that the NHA may validly expropriate the subject parcels of land.
Ratio Decidendi
On Whether the NHA may validly expropriate the parcels of land subject of these cases: The Court held that the NHA may validly expropriate the subject parcels of land. The power of eminent domain is an inherent power of the State, requiring private property, genuine necessity, public use, just compensation, and due process. The expropriation of the subject properties was directed by Presidential Decree No. 1072, issued by President Marcos who possessed legislative powers at the time, thus rendering the issue of necessity a political question. The purpose of the expropriation, which was to develop the Grace Park area under the Zonal Improvement Program (ZIP) and subdivide lots for distribution and resale at low cost to residents, falls under the broad concept of 'public use,' consistent with socialized housing mandates in the Constitution. The Court reiterated that 'public use' is a flexible concept that includes whatever is beneficially employed for the general welfare, and that the size of the property or the number of beneficiaries does not diminish its public character. On Whether the Court of Appeals erred in retroactively applying R.A. No. 7279 to exempt small property owners from expropriation: The Court ruled that the CA erred in applying R.A. No. 7279 retroactively. R.A. No. 7279 was enacted in 1992, long after the expropriation cases were initiated in 1977. The principle of non-retroactivity of laws, enshrined in Article 4 of the Civil Code, dictates that laws operate prospectively unless the contrary is provided. The Court found no indication in R.A. No. 7279 that it was intended to have retroactive application; in fact, Section 49 states it takes effect upon publication. Therefore, the exemption for small property owners under R.A. No. 7279 could not be applied to the subject expropriation cases. On Whether the determination of necessity for expropriation is a justiciable or political question: The Court clarified that while the determination of necessity is generally a justiciable question, it becomes a political question when the power of eminent domain is exercised by the Legislature or its delegate. In this case, PD No. 1072, issued by the President who had legislative powers, directed the expropriation of specific properties. Consequently, the question of necessity was deemed a political question, not subject to judicial interference, as it was a determination made by the legislative branch. On Whether the concept of 'public use' in eminent domain includes socialized housing and urban development: The Court affirmed that 'public use' is a flexible and evolving concept that encompasses socialized housing and urban development. Citing previous rulings and constitutional provisions, the Court explained that housing is a basic human need and a matter of state concern directly affecting public health, safety, and general welfare. Programs like the Zonal Improvement Program (ZIP), aimed at improving urban areas and providing low-cost housing, are considered public purposes. The Court emphasized that whatever is beneficially employed for the general welfare satisfies the requirement of public use. On Whether the size of the lots or the number of beneficiaries affects the public use character of expropriation: The Court held that the size of the lots or the number of beneficiaries does not diminish the public use character of expropriation. Citing J.M. Tuason & Co., Inc. v. Land Tenure Administration, the Court rejected the idea that property rights are inviolable to the extent of negating the State's power to expropriate for socialized housing. The Court reiterated that 'public use' now includes indirect public benefit or advantage, and that the State's policy, as expressed in the Constitution, is to promote social justice and provide housing for the greatest number of people. The fact that the expropriated lands are subdivided into smaller lots for distribution to qualified beneficiaries does not negate the public purpose.
Main Doctrine
The power of eminent domain is an inherent power of the State, subject to constitutional limitations. Its exercise requires private property, genuine necessity, public use, just compensation, and due process. The determination of necessity is a political question when legislatively delegated, and 'public use' is broadly interpreted to include socialized housing and urban development. Laws, such as R.A. No. 7279, operate prospectively unless otherwise provided, and thus cannot retroactively affect expropriation proceedings commenced before their enactment.