G.R. No. 143870 - Manila International Airport Authority vs. Rivera Village Lessee Homeowners Association, Inc.

The Manila International Airport Authority (MIAA) originated from the transfer of assets and operations of the Manila International Airport (MIA) under Executive Orders (EO) 778 and 903, with the latter vesting MIAA with the power to administer and operate the airport.
Originally, the Civil Aeronautics Administration (CAA) entered into lease contracts on May 25, 1965, with its employees for portions of a 4-hectare lot known as Rivera Village in Pasay City.
The leases were executed for a 25‑year period (May 25, 1965 to May 24, 1990) at a modest annual rental.

In January 1995, MIAA ceased issuing rental bills and refused to accept rental payments from the lessees.
Respondent, the Rivera Village Lessee Homeowners Association, acting on behalf of the lessees, requested that MIAA sell the subject property to its members by invoking relevant provisions under Presidential Decree (PD) 1517 (the Urban Land Reform Act) and PD 2016.
On February 14, 1996, MIAA denied the request on the ground that the property was reserved under its Conceptual Development Plan for airport-related activities.

The homeowners association filed a petition (Civil Case No. 97‑1598) for mandamus and prohibition, seeking:

A preliminary injunction to restrain MIAA from evicting the residents.
A directive compelling MIAA to segregate Rivera Village from its airport-related plans and requiring the National Housing Authority (NHA) to facilitate the disposition of the property in favor of the homeowners.

The lease contracts had expired, thereby depriving the petition of a cause of action.
The homeowners association did not constitute the real party in interest since the individual lessees held possessory rights.

The trial court, in its October 12, 1998 Order, dismissed the petition for lack of merit, also noting that PD 1818 barred injunctions in cases involving government infrastructure projects.

Construing the case as a class suit initiated by the homeowners association in its representative capacity.
Holding that although the lease contracts had expired, the acceptance of rental payments beyond 1990 implied a renewed lease under Article 1670 of the Civil Code.

The expiration of the original lease did not nullify rights acquired under PD 1517, Proclamation No. 1967, and PD 2016, which protect tenants from eviction in urban land reform zones.
Despite this, the issue of mandamus was not definitively resolved since it would require a full trial to ascertain whether the homeowners had acquired complete legal and vested rights.
A writ of preliminary injunction was proper to temporarily restrain MIAA from evicting the lessees, pending further proceedings.

PD 2016, which protects eviction-prone tenants in priority development zones, did not modify PD 1818’s general rule barring injunctive relief in government infrastructure cases.
The petition filed by the homeowners association failed to state a cause of action because it did not properly include the individual members as the real party in interest.
The subject property, having been reserved for airport-related activities, was exempt as required by Section 5(c) of Republic Act No. 7279.

The homeowners association was empowered by its Board Resolution to represent its members.
The rights of its members, formed under PD 1517 and PD 2016, allowed for the issuance of a writ of mandamus and preliminary injunction to prevent eviction.
Excluding such relief would violate the rights of bona fide tenants to socialized housing.

Whether PD 2016 has modified or effectively overruled PD 1818 with respect to the issuance of an injunction in cases involving government infrastructure projects.
Whether the petition filed by the Rivera Village Lessee Homeowners Association sufficiently states a cause of action, particularly in light of the requirement to litigate in the name of the real party in interest.
Whether the acceptance of rental payments beyond the expiration of the original lease contracts constitutes an implied renewal, thereby creating valid possessory rights under PD 1517 and related laws.
Whether MIAA is legally obligated to segregate the subject property from its Conceptual Development Plan and, ultimately, to dispose of it in favor of the homeowners.
Whether the issuance of a writ of mandamus (and by extension, a writ of preliminary injunction) is appropriate when the requisite clear legal right and corresponding duty have not been definitively established.