Case Digest (G.R. No. L-55166)
Facts:
Manotok v. National Housing Authority, G.R. Nos. 55166 and 55167, May 21, 1987, Supreme Court En Banc, Gutierrez, Jr., J., writing for the Court. Petitioners are owners of land comprising the Tambunting Estate and the Estero de Sunog-Apog area in Tondo, Manila; respondents are the National Housing Authority (NHA) and the Republic of the Philippines.On June 11, 1977, the President issued Letter of Instruction No. 555 (nationwide Slum Improvement and Resettlement program) and LOI No. 557 (adopting slum improvement as national policy). Pursuant thereto, the Governor of Metropolitan Manila promulgated Executive Order No. 6-77 (July 21, 1977) placing the Tambunting and Sunog-Apog sites on the Zonal Improvement Program (ZIP) priority list. A fire razed much of Tambunting on March 18, 1978; thereafter the President publicly announced government intent to acquire the estate and designated the NHA to negotiate purchase, but negotiations failed.
On December 22, 1978, Proclamation No. 1810 included the two sites in the ZIP upon presidential proclamation. On January 28, 1980, the President issued Presidential Decree (P.D.) No. 1669 (Tambunting) and P.D. No. 1670 (Sunog-Apog), each declaring the named properties expropriated and designating the NHA as administrator with authority to take possession, demolish improvements, and implement development plans. Each decree, in Section 6, directed that just compensation be pegged at market value “determined by the City Assessor pursuant to P.D. No. 76, as amended,” mandated consideration of specified “existing conditions” (e.g., alleged absence of improvements, presence of squatters) to depress valuation, fixed a maximum aggregate amount (P17,000,000 for Tambunting; P8,000,000 for Sunog-Apog), and provided for payment in five equal annual installments.
Following issuance of the decrees, the NHA sought registration with the Register of Deeds (April 4, 1980) and deposited amounts with the Philippine National Bank (July 16, 1980) that included the first installment portions. NHA advised owners they could withdraw their shares upon surrendering titles; some NHA officials instructed tenants not to pay rent to owners. Petitioner Elisa R. Manotok protested by letter (Aug. 19, 1980) alleging the decrees set unconstitutional compensation and asserting her right to refuse surrender of title. The owners filed petitions attacking the constitutionality of P.D. Nos. 1669 and 1670; lessees filed a motion to intervene (Sept. 27, 1982) claiming ownership of buildings on the properties and real-party interests.
Petitioners contended the decrees effected automatic expropriation without hearing or commencement of judicial proceedings (thus violating due process), deprived them of opportunity to contest just compensation fixed unilaterally and capped at maximums based on 1978 assessed values, and infringed equal protection by singling out property and treating improvements/tenures as nonexistent. Respondents argued eminent domain is inherent in the State, that public use and compensation fixed by the President/legislature are political questions entitled to deference unle...(Pro-only)
Issues:
- Did P.D. Nos. 1669 and 1670 deprive the petitioners of property without due process of law?
- Did P.D. Nos. 1669 and 1670 deny the petitioners just compensation as required by the Constitution?
- Did the decrees violate the petitioners' right to equal protection or otherwise improperly single out the properties for expropriation?
- Were the decrees defective or vague in providing procedures and standa...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)