Case Digest (G.R. No. L-21064)
Facts:
On August 3, 1959, Republic Act No. 2616 took effect without executive approval, expressly authorizing the expropriation of the so-called Tatalon Estate in Quezon City, then jointly owned by J. M. Tuason & Co., Inc., Gregorio Araneta & Co., Inc., Florencio Deudor, et al., for subdivision into small lots to be sold at cost to their present bona fide occupants. The property, comprising some 109 hectares covered by Transfer Certificates of Title Nos. 42774 and 49235, was occupied by approximately 1,500 families, many of whom were World War II veterans. On November 15, 1960, the Land Tenure Administration (LTA) was directed to institute expropriation proceedings before the Court of First Instance of Quezon City. Two days later, J. M. Tuason & Co., Inc. filed a special civil action for prohibition with preliminary injunction, praying that the statute be declared unconstitutional and that respondents be restrained from proceeding with the expropriation. The lower court granted a P 20,Case Digest (G.R. No. L-21064)
Facts:
- Republic Act No. 2616 and Subject Property
- On August 3, 1959, Republic Act No. 2616 (as amended by RA 3453) took effect, authorizing the expropriation of the Tatalon Estate in Quezon City (approx. 109 hectares) jointly owned by J. M. Tuason & Co., Gregorio Araneta & Co., Florencio Deudor, et al.
- The Act directed that, upon appropriation of funds for just compensation, the Land Tenure Administration (LTA) institute expropriation proceedings and sell the subdivided lots at cost to present bona fide occupants in up to 240 monthly installments with 6% annual interest.
- Proceedings Below
- On November 17, 1960, petitioner J. M. Tuason & Co., Inc. filed a special civil action for prohibition with preliminary injunction in the Court of First Instance of Quezon City, challenging RA 2616 as unconstitutional.
- The lower court granted the preliminary injunction upon a ₱20,000 bond and, after trial, on January 10, 1963 declared RA 2616 unconstitutional, issued a permanent writ of prohibition, and enjoined respondents from instituting expropriation proceedings; respondents appealed.
Issues:
- Procedural Questions
- Whether a special civil action for prohibition may be maintained against the government and its officials without the State’s consent.
- Whether the Executive Secretary, as purported real party in interest, must be impleaded.
- Constitutional Questions
- Whether Congress validly exercised its power under Article XIII, Section 4 of the 1935 Constitution to authorize expropriation of a specific land for subdivision and resale at cost.
- Whether the taking pursuant to RA 2616 serves a public use and is accompanied by just compensation.
- Whether RA 2616 satisfies due process (absence of arbitrariness) in authorizing the expropriation.
- Whether RA 2616 denies petitioner equal protection by singling out the Tatalon Estate.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)