Case Digest (G.R. No. 133250)
Facts:
On April 27, 1998, Francisco I. Chavez filed a petition under Rule 65 seeking to compel the Public Estates Authority (PEA) to disclose all documents related to its negotiations with Amari Coastal Bay Development Corporation (Amari) on the Manila–Cavite Coastal Road and Reclamation Project and to enjoin any new agreement vesting reclaimed lands in Amari. In its July 9, 2002 en banc decision penned by Justice Antonio T. Carpio, the Supreme Court summarized that (1) the 157.84 hectares of reclaimed foreshore lands now titled in PEA’s name are alienable public lands that PEA may only lease or sell to Filipino citizens, not private corporations; (2) the 592.15 hectares of submerged areas of Manila Bay are inalienable natural resources until reclaimed and classified as alienable agricultural land; and (3) the Amended Joint Venture Agreement (Amended JVA) transferring 77.34 hectares of Freedom Islands and 290.156 hectares of still submerged areas to Amari is void ab initio for violatinCase Digest (G.R. No. 133250)
Facts:
- Parties and Contractual Background
- Petitioner Francisco I. Chavez sued respondents Public Estates Authority (PEA) and Amari Coastal Bay Development Corporation (“Amari”) over an Amended Joint Venture Agreement (AJVA) for reclaiming and developing portions of Manila Bay.
- Original JVA (1995) and its 1999 amendment covered:
- 157.84 ha of partially reclaimed “Freedom Islands” (titled in PEA).
- 592.15 ha of still-submerged seabed.
- An option to reclaim an additional 350 ha.
- Under the AJVA, Amari agreed to shoulder full reclamation costs and reimburse PEA’s past expenses (P1.894 billion), in exchange for 70% of the “net usable area” (up to 367.5 ha) by title or cash.
- Lower Proceedings and Motions
- Chavez filed a petition (April 1998) to compel PEA to disclose contract negotiations and enjoin AJVA execution, invoking the people’s right to information.
- The Court’s Decision of July 9, 2002 held the AJVA null and void ab initio for violating Sections 2 and 3, Article XII of the 1987 Constitution and Civil Code Art. 1409.
- Post-Decision motions included:
- Amari’s Motion to Inhibit Justice Carpio (bias/prejudgment) and for Re-Deliberation;
- Amari’s Motion for Oral Argument;
- Amari’s Motions for Reconsideration/Supplement;
- PEA’s Motions for Reconsideration/Supplement;
- Office of the Solicitor General’s Motion for Reconsideration/Clarification.
- Supreme Court Decision (July 9, 2002) – Key Holdings
- 157.84 ha reclaimed lands: alienable public domain; PEA may lease to private corporations but may only sell to Filipino citizens (Sec. 3, Art. XII).
- 592.15 ha submerged areas: inalienable natural resources; outside commerce until reclaimed and reclassified.
- AJVA’s transfers to Amari of both reclaimed and submerged lands violate Sections 2 and 3, Art. XII; contract void ab initio.
- Civil Code Art. 1409 renders contracts with objects contrary to law or outside commerce inexistent and void.
- Amari’s Defenses and Arguments
- Alleged absence of public bidding not a ratio decidendi; OSG conceded the bidding flaw.
- Prior newspaper columns of Justice Carpio on public bidding did not disqualify him.
- Request for prospective application based on doctrines in De Agbayani v. PNB (1971) and Spouses Benzonan (1992) – rejected as no law or doctrine was reversed.
- Equity arguments: alleged good-faith reliance, partial payment, and “whopping” project cost.
Issues:
- Motions Relating to the Decision
- Should Justice Carpio inhibit himself for alleged bias/prejudgment?
- Should the case be set for oral argument?
- Should the Court reconsider its July 9, 2002 Decision?
- Contractual and Constitutional Issues
- Are the reclaimed and submerged areas alienable/disposable public lands or inalienable?
- Does the AJVA’s transfer of public domain lands to a private corporation violate Sections 2 and 3, Article XII of the 1987 Constitution?
- Should the Decision apply retroactively or prospectively?
- Authority of PEA and Rights of Private Corporations
- Does PEA have a constitutional or statutory power to sell reclaimed lands to private corporations?
- Can private corporations enter into joint-venture or other agreements involving reclaimed lands as compensation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)