G.R. No. L-58058 - Mendoza vs. National Housing Authority

The petitioners — Santiago Mendoza, Carmen Urbano, Manuela Urbano, Renato de Guzman, Raquel de Guzman, Rosette de Guzman, and Romeo de Guzman — occupied portions of the Tatalon Estate in Quezon City.
Each group of petitioners claimed title to distinct portions of the estate through various instruments:

Santiago Mendoza claimed ownership over an 8.5-hectare portion through an Agreement executed on December 4, 1969.
Carmen Urbano and Manuela Urbano based their claim to a 1,500 square meter lot on a Deed of Transfer dated May 4, 1951.
Renato, Raquel, Rosette, and Romeo de Guzman claimed title to a 1,700 square meter portion inherited from their father, who in turn acquired the property on September 6, 1957.

On August 3, 1959, Republic Act No. 2616 took effect authorizing the expropriation of the Tatalon Estate for subdivision and resale to bona fide occupants, despite the absence of executive approval.
Before the government could file a complaint for eminent domain, J.M. Tuason and Co., Inc. filed an action for prohibition with the trial court, seeking to declare the law unconstitutional and to restrain the Land Tenure Administration from proceeding with the expropriation.
Initially, the lower court ruled in favor of the prohibition and declared Republic Act No. 2616 unconstitutional.
On appeal, the Supreme Court reversed the lower court’s decision and denied the petition for prohibition.

On October 27, 1972, by Letter of Instruction No. 34 under Proclamation No. 1081, the President directed the People’s Homesite and Housing Corporation to negotiate or expropriate the Tatalon Estate for developing housing projects under the provisions of RA 2616.
The People’s Homesite and Housing Corporation subsequently filed a complaint for condemnation on January 23, 1973, leading to the expropriation of parts of the estate.
A Compromise Agreement was reached on July 28, 1978 between the Republic, through the National Housing Authority, and J.M. Tuason and Co., Inc. This agreement set the just compensation for a 25.26-hectare portion of the estate and provided for its cancellation from the title and reissuance in the name of the National Housing Authority.
Presidential Decree No. 1261, issued on December 12, 1977, designated the National Housing Authority as the administrator of the Tatalon Estate Housing Project, and provided guidelines for lot allocation based on priority listings.

On June 11, 1978, Presidential Decree No. 1472 was issued authorizing the National Housing Authority to summarily eject squatters or illegal occupants from government resettlement projects without a judicial order, provided proper notice was given.
Subsequent actions by the National Housing Authority included:

A demolition order directed at petitioner Manuela Urbano on January 27, 1981, due to her status as an absentee structure owner for Lot Nos. 16 and 18, Block 523.
A letter of reconsideration on June 2, 1981, which though reconsidering the petition for allocation under the third priority among squatter families, did not alter the demolition order.
A similar order for petitioners Romeo de Guzman and Renato de Guzman that maintained their classification as absentee structure owners and denied their petition for lot allocation.
An order for Santiago Mendoza on August 27, 1981, to demolish an illegal structure encroaching on adjacent lot boundaries.

Facing the threat of demolition, the petitioners filed the present recourse alleging that the enforcement of PD 1472 violated constitutional due process by effectively depriving them of their property rights.

The petitioners maintained that they were the rightful owners of the lots they occupied, having acquired them from the DEUDORS.
However, the properties in dispute belonged to the Republic of the Philippines following the expropriation proceedings under RA 2616, which transferred title to the government.
The petitioners had submitted their names for inclusion as “Tatalon Estate beneficiaries,” thereby implicitly acknowledging government ownership.
Detailed surveys and subdivision of the estate revealed that the lots occupied by petitioners were part of the unsold parcels included in the expropriation and subsequent Compromise Agreement.

Whether the petitioners, claiming ownership of the land, were entitled to relief through a petition for prohibition to restrain the demolition of their houses.
Whether the National Housing Authority had jurisdiction over the properties in question, considering they were part of the expropriated Tatalon Estate.

Whether Presidential Decree No. 1472, which authorized summary ejectment of squatters without a judicial order, violated the constitutional due process clause.
Whether the method of notice (personal service or by posting) as required by PD 1472 sufficed to meet due process standards.

Whether the petitioners’ claims that they owned the lots they occupied were viable, given that the properties had already been expropriated and registered in the name of the government.
Whether the proper legal remedy was via expropriation proceedings rather than a petition for prohibition.

Whether the nature of a writ of prohibition is appropriate in preventing enforcement actions by an administrative authority in this context.
Whether the petitioners’ cause of action for injunction (if any) was properly transformed into a petition for prohibition.