Title
MaNo.a vs. Court of Appeals
Case
G.R. No. 106440
Decision Date
Jan 29, 1996
Land expropriated for historical landmark status upheld as public use; no constitutional violation despite religious figure's birthplace; due process observed.

Case Digest (G.R. No. 106440)
Expanded Legal Reasoning Model

Facts:

  • Background
    • Petitioners Alejandro, Asuncion and Leonica Manosca inherited a 492-square-meter parcel of land situated on P. Burgos Street, Calzada, Taguig, Metro Manila.
    • The National Historical Institute (NHI), under Section 4 of Presidential Decree No. 260, passed Resolution No. 1, Series of 1986, declaring the parcel as the birthsite of Felix Y. Manalo—a national historical landmark—which was approved by the Minister of Education, Culture and Sports on January 6, 1986.
  • Procedural History
    • On May 29, 1989, the Republic of the Philippines, through the Office of the Solicitor General, filed a complaint for expropriation in the Regional Trial Court (RTC) of Pasig, Branch 168, seeking to acquire the lot for “public use” as a national historical landmark. Simultaneously, it moved for immediate possession upon deposit of the provisional amount.
    • The RTC issued on August 3, 1989 an order fixing the provisional market value at ₱54,120.00 and assessed value at ₱16,236.00, authorizing possession upon deposit. Petitioners moved to dismiss the complaint on grounds that (a) the expropriation lacked public purpose and (b) it violated Section 29(2), Article VI of the 1987 Constitution by indirectly benefiting a religious entity. They also sought suspension of the possession order.
    • The trial court denied the motion to dismiss on February 15, 1990; declared the motion for reconsideration moot on February 20, 1990; and further denied reconsideration on April 16, 1991.
    • Petitioners then filed a petition for certiorari and prohibition with the Court of Appeals, which, in a decision dated January 15, 1992, dismissed the petition for lack of grave abuse of discretion and availability of adequate remedy by appeal. Its July 23, 1992 resolution denied reconsideration. Petitioners elevated the case by petition for review on certiorari to the Supreme Court.

Issues:

  • Whether the attempted expropriation of the Manosca parcel declared as a national historical landmark satisfies the “public use” requirement under the Constitution.
  • Whether petitioners were denied due process in the fixing of the provisional value and in the ex parte possession order.
  • Whether the existence of a prior contract (exchange agreement) between petitioners and Iglesia ni Cristo forecloses the need for expropriation under Noble v. City of Manila.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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