A.M. No. MTJ-99-1176 - Mallorca vs. Panopio

On January 19, 2004, the City Council of Manila enacted Ordinance No. 8070 authorizing the Mayor to acquire private parcels for its Land-For-The-Landless Program.
Petitioner offered respondents ₱2,000.00 per square meter by negotiated sale, which respondents refused as inadequate.

On September 3, 2004, petitioner filed an expropriation complaint under Rule 67, depositing ₱4,812,920.00 (100% of assessed value).
The RTC denied a writ of possession until an additional ₱852,519.00 (15% of fair market value) was deposited, per LGC requirements.
Petitioner and prospective beneficiaries deposited the required sum; on October 6, 2006, the RTC issued a writ of possession.
The RTC, in a June 23, 2011 Order, granted the complaint, finding all requisites for eminent domain met, and denied reconsideration on January 22, 2013.

On appeal (CA-G.R. CV No. 101440), the CA emphasized strict compliance with constitutional and statutory limitations on eminent domain.
The CA concluded petitioner failed to:

Prove that on-site development was practicable and that the properties met the statutory definition of “blighted” lands (RA 7279).
Exhaust other acquisition modes (no renegotiation after initial offer).
Show that beneficiaries were “underprivileged and homeless” (RA 7279).

The CA reversed and set aside the RTC Order on June 30, 2015, and denied reconsideration on November 9, 2015.

Whether petitioner complied with Section 19 of the Local Government Code (LGC) in exercising its delegated power of eminent domain.
Whether petitioner observed the priorities and substantive requirements of Republic Act No. 7279 (RA 7279) in:

Whether petitioner exhausted negotiation and other modes of acquisition before filing the expropriation suit.