Case Digest (G.R. No. L-14111)
Facts:
National Resettlement and Rehabilitation Administration v. Teresa R. de Francisco, G.R. No. L-14111. October 24, 1960, the Supreme Court En Banc, Reyes, J., writing for the Court. The appeal was taken on points of law from a judgment of the Court of First Instance of Nueva Ecija (Civil Case No. 2006) dismissing condemnation (eminent domain) proceedings instituted by NARRA.
On June 11, 1955, Republic Act No. 1266 became operative, authorizing NARRA to expropriate the Hacienda del Rosario in Valdefuente, Cabanatuan City, to subdivide the estate into lots not exceeding one hectare and resell them to bona-fide occupants at a price including expropriation and subdivision costs payable in installments. Pursuant to that statute, NARRA instituted condemnation proceedings in the Court of First Instance against the heirs of the original owner, the late Judge Simplicio del Rosario, and various subsequent vendees.
The hacienda amounted to about 669 hectares. During the proceedings several heirs—Dolores R. de Concepcion, Teresa R. de Francisco, and Paz R. de Tubangui—and the spouses Carmen R. de Ciocon and Jaime Ciocon voluntarily ceded portions, resulting in NARRA acquiring approximately 391.7583 hectares. The remaining defendants were purchasers and sub-acquirers who held parcels ranging from one-half to thirteen hectares, acquired between 1949 and 1954 (i.e., before the passage of R.A. 1266).
The trial court (Court of First Instance of Nueva Ecija) dismissed the condemnation as to the remaining defendants, relying on this Court’s prior decisions in Republic v. Baylosis (96 Phil. 461) and Rural Progress Administration v. Guido (84 Phil. 847), and holding that once a landed estate has been broken into reasonably sized parcels it is no longer the large landed estate contemplated by Article XIII, Sec. 4 of the Constitution and thus not subject to further expropriation. The trial court also found as fact that the families meant to be benefited by the expropriation could be accommodated within the area already acquired by NARRA and that the 85.0414 hectares the Ciocon spouses sought to reserve were not a “big landed estate” within the constitutional meaning.
NARRA appealed, arguing that the cited precedents involved e...(Subscriber-Only)
Issues:
- Are precedents construing expropriation authority under Commonwealth Act No. 539 applicable to expropriation proceedings instituted under Republic Act No. 1266, given both rest on Article XIII, Section 4 of the Constitution?
- May NARRA lawfully expropriate the remaining small parcels and the 85.0414-hectare portion of the former Hacienda del Rosario that had been segregated o...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)