Case Digest (G.R. No. 236596) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In City of Mandaluyong v. Aguilar, G.R. No. 137152 (January 29, 2001; decision November 11, 2002), the City of Mandaluyong (petitioner) filed on August 4, 1997 before the RTC of Pasig City a complaint for expropriation against Antonio N. Aguilar, Francisco N. Aguilar, Thelma N. Aguilar, Eusebio N. Aguilar (deceased), Rodolfo N. Aguilar and their heirs (respondents), seeking two contiguous parcels totaling 1,636 sq.m. at 9 de Febrero St., Mauwag, Mandaluyong. The lots, once three parcels of 1,847 sq.m., bore decades-old residential houses leased to tenants and informal occupants. In 1983 the area was declared an Area for Priority Development under P.D. 1517 and later under R.A. 7279, prompting a tenants’ association to petition the Sangguniang Panlungsod, which on November 7, 1996 adopted Resolution No. 516 authorizing the mayor to negotiate acquisition at ₱3,000/sq.m. Respondents denied receipt of the offer, contested the “fair market value” and claimed exemption as “small prope Case Digest (G.R. No. 236596) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Filing of Expropriation Complaint
- On August 4, 1997, the City of Mandaluyong (petitioner) filed an expropriation complaint under SCA No. 1427 before the Regional Trial Court (RTC), Branch 168, Pasig City, against Antonio N., Francisco N., Thelma N., Eusebio N., Rodolfo N., all surnamed Aguilar (respondents), for three adjoining parcels totalling 1,847 sqm (TCTs 59780, 63766, 63767) at Barangay Mauwag, Mandaluyong.
- Portions were occupied by respondents’ tenants in residential houses; other occupants had built on the vacant portion.
- In 1983, the Housing and Urban Development Coordinating Council classified the lots as an Area for Priority Development (APD) under Proclamations 1967 and 2284.
- On November 7, 1996, the Sangguniang Panlungsod adopted Resolution No. 516 authorizing expropriation and condominium construction; on January 10, 1996, Mayor Abalos offered P3,000/sqm by negotiated purchase, to which respondents did not reply.
- Respondents’ Answer and Preliminary Hearing
- Respondents denied receipt of the purchase offer, alleged arbitrariness, lack of public purpose, and undervaluation (BIR zonal value P7,000/sqm), and counterclaimed P21 million damages.
- They moved for a preliminary hearing to dismiss for lack of jurisdiction and cause of action. Petitioner replied.
- Amended Complaint and Trial Court Proceedings
- On November 5, 1997, petitioner filed an Amended Complaint naming an additional defendant, Virginia N. Aguilar, substituted heirs of Eusebio (deceased 1995), and dropped TCT 59780, reducing expropriation area to 1,636 sqm under TCTs 63766, 63767.
- Respondents adopted their prior pleadings; at the February 25, 1998 hearing, they presented testimony and documents; petitioner presented no evidence.
- On September 17, 1998, the RTC dismissed the Amended Complaint: (a) respondents are “small property owners” exempt under R.A. 7279; (b) petitioner failed to prove public purpose or beneficiary homelessness/landlessness. Motion for reconsideration was denied on December 29, 1998.
Issues:
- Do respondents qualify as “small property owners” exempt from expropriation under Section 3(q) of R.A. 7279?
- Did the City of Mandaluyong comply with R.A. 7279’s requirement to exhaust alternative modes of acquiring land (Section 10) before resorting to expropriation?
- Was the 1998 partition of the co-owned lots effected in bad faith to circumvent statutory exemptions?
- Was the expropriation action for a valid public purpose and targeted at qualifying beneficiaries?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)