Title
De Knecht vs. Bautista
Case
G.R. No. L-51078
Decision Date
Oct 30, 1980
Government arbitrarily changed EDSA extension route, expropriating properties without justification, violating due process and equal protection; Supreme Court nullified writ of possession, halting expropriation.
A

Case Digest (G.R. No. L-51078)

Facts:

  • Project inception and administrative actions
    • In 1969, the Department of Public Works and Communications (now MPH) planned to extend Epifanio de los Santos Avenue (EDSA) to Roxas Boulevard via Cuneta Avenue as part of the Manila–Cavite Coastal Road Project.
    • On December 13, 1974, Secretary Baltazar Aquino directed the Pasay City Engineer to halt issuance of building permits along Cuneta Avenue. Shortly thereafter, the Ministry of Public Highways decided to reroute the extension through Fernando Rein and Del Pan Streets.
  • Petition to the President and Human Settlements Commission review
    • On April 15, 1977, owners affected by the new route (including petitioner Cristina de Knecht) petitioned President Marcos to revert to the original Cuneta alignment. The President referred the matter to the Human Settlements Commission (HSC).
    • After formal hearings, the HSC recommended on July 4, 1977, that the extension revert to Cuneta Avenue based on functionality, minimal cost difference, and lower social impact; it also urged comprehensive relocation plans and negotiated compensation. The Ministry of Public Highways nevertheless pursued the Del Pan–Fernando Rein alignment.
  • Lower court expropriation proceedings
    • In February 1979, the Republic filed Civil Case No. 7001-P for expropriation in the Pasay City Branch III, naming owners along Fernando Rein and Del Pan Streets. On March 19, 1979, petitioner moved to dismiss for lack of jurisdiction, failure to comply with PD Nos. 824, 1396 and 1517, arbitrary property selection, premature filing, and erroneous valuation; she also sought a preliminary injunction.
    • In June 1979, after the Republic deposited just compensation, the respondent judge issued on June 14, 1979 a writ of possession allowing immediate entry onto the properties. Cristina de Knecht then filed a petition for certiorari and prohibition to annul that order.

Issues:

  • Jurisdiction and discretion
    • Whether the respondent judge lacked or exceeded jurisdiction or gravely abused discretion by issuing the writ of possession despite pending constitutional and statutory questions.
  • Validity of route selection
    • Whether the choice of Fernando Rein–Del Pan alignment was arbitrary, capricious, or in bad faith—thus violating due process and equal protection—when the original Cuneta route was technically superior and recommended by the HSC.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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