G.R. No. L-8892 - Halili vs. Lacson

Alfredo Halili, Tomas P. Jacob, and forty-one other occupants owning respective houses inside the Palomar Compound, Tondo, Manila.
Occupation commenced around 1945, 1946, and 1947 following the devastation of war, when many lost their homes.

The City of Manila, as a party in interest, intervened in the proceedings due to its dominion over public land matters.

Petitioners erected their houses inside the Palomar Compound without prior formal authority from the city.
The City, upon discovering the occupation, opted to tolerate the occupants’ presence given the post-liberation circumstances.

Two petitioners, Halili and Jacob, eventually secured a written permit from the then City Mayor.
The permits were characterized not as bona fide leases but as concessions extended under limited conditions.

The permission could be revoked by the mayor at any time with thirty days’ notice.
Removal of structures was mandated if city planning for Greater Manila affected the premises; the removal was to be executed within a reasonable period as set by the City Engineer, without cost to the government.
All expenses for removal of the structures were to be borne by the petitioners should they fail to comply within the specified period.
No permanent structure was to be erected on the property.
Petitioners were bound to comply with any future directives by the city regarding the premises.

On May 5, 1952, respondents issued an order for the demolition of the houses, citing that they constituted a public nuisance obstructing public areas such as streets, parks, plazas, and esteros.
The order required petitioners to vacate and remove the structures within thirty days, with a warning that failure would lead to demolition at their own expense under the Revised Ordinance of the City of Manila.

With joined issues and sufficient factual basis, the lower court ruled “without further hearing,” dismissing the petition and affirming the order for vacating and demolition.
Petitioners then appealed this decision.

Claimed that their prior occupancy and the alleged lease agreements conferred a contractual right to remain, thus rendering the demolition order arbitrary and illegal.
Asserted that even if the permits were defective, they were entitled to a refund of the nominal rentals paid, based on provisions of Article 1412 of the New Civil Code.
Contended that the reservation of the Palomar Compound as a school site should not negate their rights secured by said contracts.

Asserted that the occupation occurred without proper authority, aside from the subsequent limited permits issued only to Halili and Jacob under strict conditions.
Emphasized that the occupation resulted in a public nuisance, justifying the demolition action under Section 1122 of the Revised Ordinance of the City of Manila.
Argued that the permits were merely acts of clemency and did not constitute guaranteed leases, so the condition to vacate when required by the city was binding.

Whether the demolition order issued by the respondents was legally proper and within their authority.
Whether the occupation of the Palomar Compound by the petitioners, including those with permits, was initially unauthorized and subject to revocation.
Whether the written permits (or so-called lease contracts) secured by Halili and Jacob conferred any legal right that would prevent the demolition order.
Whether petitioners were entitled to a refund of the nominal rentals paid under any purported lease agreement, particularly under Article 1412 of the New Civil Code.