Case Digest (G.R. No. 78742) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On July 14, 1989, the Supreme Court, En Banc, resolved four consolidated petitions challenging the constitutional validity of presidential decrees, executive orders, a proclamation, and a statutory agrarian reform law enacted to implement a comprehensive agrarian reform program under the 1987 Philippine Constitution. In G.R. No. 78742, Association of Small Landowners in the Philippines, Inc. and individual landowners (including Nicolas S. Manaay and Agustín Hermano, Jr.) sought a writ of mandamus against the Department of Agrarian Reform (DAR) for allegedly refusing to issue implementing rules under P.D. No. 27 and related issuances, thus frustrating their right of retention on rice and corn lands not exceeding seven hectares. In G.R. No. 79310, planters and sugarlandowners in Victorias Mill District (e.g., Arsenio Acuña and Newton Jison) moved to prohibit enforcement of Presidential Proclamation No. 131 and E.O. No. 229, arguing that the President lacked legislative power to Case Digest (G.R. No. 78742) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Consolidation of Cases
- G.R. No. 78742 – Association of Small Landowners challenges Presidential Decree No. 27 (PD 27), Executive Orders Nos. 228 and 229.
- G.R. No. 79310 – Sugar planters and Planters’ Committee, Inc. challenge Proclamation No. 131 and EO 229, especially the ₱50 billion Agrarian Reform Fund.
- G.R. No. 79742, 79744, 79777 – Individual landowners (Manaay, Hermano, Acuña, Jison, Ferraris, Pabico) seek mandamus or prohibition and question coverage, retention, valuation, compensation methods under PD 27, EO 228/229, RA 6657.
- Legal and Historical Background
- Constitutional Mandates – 1935, 1973, and 1987 Constitutions require agrarian reform, social justice, equitable land distribution.
- Statutory Evolution – RA 3844 (1963), PD 27 (1972), EO 228/229 & Proc. 131 (1987), RA 6657 Comprehensive Agrarian Reform Law (1988).
- Petitioners’ Allegations – Unconstitutional expropriation (no due process, no just compensation in cash), separation of powers, invalid appropriation, absence of retention limits, unequal treatment.
- Government’s Defense – Presumption of constitutionality; valid exercise of martial-law and Transitory Provisions powers; preliminary administrative valuation with full judicial review; proper classification; appropriation valid until Congress convened; retention rules issued.
Issues:
- Authority and Continuity of Measures
- Was the President empowered to issue PD 27, EO 228/229, Proc. 131 under martial law or the 1987 Constitution’s Transitory Provisions?
- Have subsequent laws (notably RA 6657) repealed or rendered these measures obsolete?
- Separation of Powers
- Did the President usurp legislative authority by issuing agrarian reform measures before Congress convened or by failing to respect legislative functions?
- Due Process and Expropriation
- Does expropriation under these measures afford owners judicial determination of just compensation?
- Is transfer of title prior to full cash payment a due process violation?
- Equal Protection and Classification
- Are agricultural landowners improperly singled out or overburdened without similar obligations on other property owners?
- Does absence or inadequacy of retention limits deny owners equal protection?
- Just Compensation
- Must just compensation be paid solely in money, or is a mix of cash, bonds, shares, tax credits, and other instruments constitutional?
- Does administrative summary valuation usurp judicial prerogatives?
- Appropriation of Funds
- Is the ₱50 billion Agrarian Reform Fund appropriation valid, or is it an in futuro, uncertified, and unconstitutional appropriation?
- Administrative Remedies and Mandamus
- Have petitioners exhausted adequate remedies before coming to court?
- Is mandamus available to compel issuance of retention rules under PD 27?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)