Case Digest (G.R. No. L-11527)
Facts:
In Iron and Steel Authority (ISA) v. Court of Appeals and Maria Cristina Fertilizer Corporation (MCFC), G.R. No. 102976, decided October 25, 1995, the petitioner ISA, created by P.D. No. 272 on August 9, 1973 to develop the local steel industry, was empowered to expropriate land “for and on behalf of the Government.” When ISA’s initial five-year term ended on October 10, 1978, it was extended until August 11, 1988. Meanwhile, the National Steel Corporation (NSC), a government subsidiary, planned a major steel mill in Iligan City. By Proclamation No. 2239 and LOI No. 1277 (both November 16, 1982), certain public lands occupied by MCFC’s idle fertilizer plant were reserved for NSC, and ISA was directed to expropriate MCFC’s occupancy rights if negotiations failed. After sixty days without agreement, ISA filed eminent domain proceedings in the Iligan Regional Trial Court on August 18, 1983, impleading MCFC and the Philippine National Bank. A writ of possession issued September 17,Case Digest (G.R. No. L-11527)
Facts:
- Creation and Mandate of the ISA
- Presidential Decree No. 272 (9 August 1973) created the Iron and Steel Authority (ISA) for five years to develop and promote the Philippine iron and steel industry.
- Objectives included industry strengthening, market expansion, consolidation, rationalization, price stabilization, capacity utilization, and raw‐material security.
- Powers under Sec. 4(j) included initiating expropriation of land for basic iron and steel facilities when necessary to fulfill ISA objectives.
- Original term expired 10 October 1978; extended by Executive Order No. 555 (31 August 1979) for ten more years.
- NSC Expansion and Land Reservation
- National Steel Corporation (NSC), a government‐owned subsidiary, planned an integrated steel mill in Iligan City.
- Proclamation No. 2239 (16 November 1982) withdrew ~30.25 ha in Iligan from disposal and reserved it for NSC.
- Letter of Instruction No. 1277 (16 November 1982) directed NSC to negotiate compensation with Maria Cristina Fertilizer Corporation (MCFC) for its occupancy; failing agreement within 60 days, ISA to expropriate occupancy rights and related facilities for NSC.
- Expropriation Proceedings and Expiration of ISA’s Term
- ISA filed expropriation in Iligan RTC (18 August 1983), depositing ₱1,760,789.69 (10% of declared value), and impleaded MCFC and Philippine National Bank.
- Writ of possession issued (17 September 1983); NSC placed in possession. Trial ensued.
- ISA’s statutory term expired on 11 August 1988. MCFC moved to dismiss for lack of a juridical plaintiff (Rule 3, Secs. 1 & 16, Rules of Court).
- RTC granted the motion (9 November 1988), dismissing the case; MCFC argued ISA ceased to exist and no successor was named.
- ISA’s motion for reconsideration was denied; RTC further ruled the land was for NSC’s private benefit, not public use.
- Court of Appeals (8 October 1991) affirmed: ISA had no wind‐up period after term expiration and could not delegate its powers to the Republic.
Issues:
- Can the Republic of the Philippines be substituted as party‐plaintiff for ISA upon ISA’s statutory term expiration?
- If substitution is possible, is fresh legislative authority needed for the Republic to continue expropriation proceedings?
- Are the questions of public use and just compensation properly resolvable before trial on the merits?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)