G.R. No. L-20141-42 - Cuatico vs. Court of Appeals

On May 7, 1959, J. M. Tuason & Co., Inc. filed an action in the Court of First Instance of Rizal, Quezon City for ejectment against Joaquin Cuatico over a parcel of land in Tatalon Estate.
Cuatico answered the complaint and also filed a counterclaim for damages.
On September 24, 1959, Cuatico sought to file a third-party complaint to include the persons from whom he claimed to have acquired the disputed land—Pedro and Florencio Deudor Deodati Gochangco and Virginia T. Martinez. The lower court denied his motion due to opposition by the plaintiff.

On May 31, 1960, the lower court ruled in favor of J. M. Tuason & Co., Inc., declaring it the owner of the property and ordering Cuatico to vacate the premises and remove his house, while imposing a rental payment of ₱90.00 per month from April 1950 until possession was restored.
Cuatico appealed the decision to the Court of Appeals.
On July 7, 1962, Cuatico filed with the Court of Appeals a petition to suspend the further prosecution of the case, invoking Section 4 of Republic Act No. 2616 as amended by Republic Act No. 3453.
The petition for suspension was based on the new provision that barred the initiation or continuation of ejectment proceedings on any lot forming part of the Tatalon Estate.

On March 18, 1960, Cuatico along with Deudati Gochangco filed a separate complaint in the same Court of First Instance against J. M. Tuason & Co., Inc. and others to compel execution of deeds of transfer for the lot, or alternatively, to secure damages if plaintiffs were found not to have any rights in the property.
This complaint, docketed as Civil Case No. Q-5062, was later amended to add additional parties, including Cuatico’s wife.
The lower court dismissed this complaint on August 31, 1960.
As in the first action, on July 7, 1962, a petition for suspension invoking the amended act was filed, which was eventually denied by the Court of Appeals on July 20, 1962.

Republic Act No. 2616, approved on August 3, 1959, originally provided that once expropriation proceedings had been initiated on any lot within the Tatalon Estate, no ejectment proceedings could be instituted or continued.
Republic Act No. 3453, approved on June 16, 1962, amended the provision by eliminating the prerequisite of actual expropriation proceedings. It mandated that upon its approval, ejectment proceedings against the present occupants were automatically barred, essentially suspending any further legal action aimed at recovering possession.
Petitioners, the occupants of the premises, invoked the benefit of the amended act seeking suspension of ejectment proceedings at a stage when no expropriation had actually commenced.

Petitioners contended that the amended provision was valid and applicable to their case, thereby preventing the continuation or institution of ejectment actions.
Respondents argued that if interpreted broadly as barring such actions before the government commenced expropriation proceedings, the law would lead to confiscation of private property without due process or just compensation—a violation of constitutional rights.

Whether Section 4 of Republic Act No. 3453, which prohibits the institution or prosecution of ejectment proceedings against occupants of any lot in the Tatalon Estate even in the absence of expropriation proceedings, is constitutional and valid.
Whether the Court of Appeals abused its discretion by denying the petitions for suspension of ejectment proceedings filed by Cuatico and his co-plaintiffs, given the new legislative amendment.
The extent to which the amended provision affects the dominical rights of a landowner without the concurrent initiation of expropriation proceedings or deposition of just compensation.