Facts:
Benjamin Rabuco et al., Petitioners sued
Hon. Antonio J. Villegas, later substituted by
Hon. Ramon Bagatsing as City Mayor of Manila, and other city officials and administrators of the Land Reform Authority, seeking injunction and mandamus to prevent demolition of their houses and ejectment from Lot 21-B, Block 610 (San Andres, Malate), and to compel implementation of
Republic Act 3120 enacted June 17, 1961, which converted certain communal city lots into disposable lands of the State for subdivision and sale on installment to tenants and bona fide occupants and expressly prohibited ejectment and demolition of such occupants. The trial court dismissed the petition, found the petitioners’ dwellings to be public nuisances and ordered ejectment and demolition, and denied injunction. Petitioners appealed to the Court of Appeals (dockets CA-G.R. Nos. 35269 and 35453), which issued a writ of preliminary injunction in a related, emergency petition and later certified to this Court the dominant question of the constitutionality of
Republic Act 3120. The Supreme Court issued a preliminary injunction on August 17, 1965, and the record shows that a fire on April 19, 1970 destroyed the petitioners’ houses, prompting a temporary restraining order on June 17, 1970 to prevent interference with petitioners’ possession pending final determination; the appeal and the certified questions were thereafter considered by this Court, which reached final decision on February 28, 1974.
Issues:
Is
Republic Act 3120 unconstitutional for depriving the City of Manila of property without due process and without just compensation in violation of the Constitution? Did the City Mayor and City Engineer have authority to demolish and eject petitioners despite the prohibitions of
Republic Act 3120? Does the conversion by Congress of municipally titled communal land into disposable or alienable lands of the State for disposition to bona fide occupants constitute an exercise of the power of eminent domain requiring compensation?
Ruling:
Ratio:
Doctrine: