Case Digest (G.R. No. L-3900)
Facts:
- On January 30, 1947, the Republic of the Philippines, through the Rural Progress Administration, began expropriation proceedings in the Manila Court of First Instance under Commonwealth Act No. 539.
- The properties involved belonged to Dr. Leon Samia and Vicente Pineda, located in Santa Cruz, Manila, covering a total area of 5,593 square meters, occupied by about fifty-seven tenants.
- The government aimed to subdivide the land into smaller lots for resale to the tenants.
- It was revealed that Leon Samia had transferred portions of his land to his three married children, leading to their inclusion as additional defendants.
- The court provisionally valued the properties at P6,769 and ordered the sheriff to place the plaintiff in possession after a monetary deposit.
- The defendants argued that the lands were small lots and not subject to expropriation under Commonwealth Act No. 539, resulting in multiple motions to dismiss, which the court deferred.
- The defendants sought damages for unpaid rentals from the plaintiff and tenants, which the court allowed.
- On March 12, 1948, the defendants requested to withdraw P3,700 from the deposit for back rentals; the court partially granted this, allowing a withdrawal of P3,000.
- The defendants later reiterated their motion to dismiss based on a recent Supreme Court ruling in Guido v. Rural Progress Administration, leading to the trial court dismissing the expropriation action without prejudice to the defendants' claims for back rentals.
- The plaintiff and third-party defendants appealed, claiming the trial court erred in dismissing the complaint and allowing the withdrawal of funds.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the trial court's dismissal of the expropriation complaint, agreeing that the properties did not qualify as "large estates" under constitutional provisions for expropriation.
- The Court upheld the trial court's decision to allow the withdrawal of P3...(Unlock)
Ratio:
- The Supreme Court's ruling was based on the interpretation of constitutional provisions regarding expropriation, specifically Article XIII, Section 4, which permits the expropriation of "large estates" for subdivision and resale.
- The Court reiterated its previous decision in Guido v. Rural Progress Administration, emphasizing ...continue reading
Case Digest (G.R. No. L-3900)
Facts:
On January 30, 1947, the Republic of the Philippines, represented by the Rural Progress Administration, initiated expropriation proceedings in the Manila Court of First Instance under Commonwealth Act No. 539. The properties in question belonged to Dr. Leon Samia and Vicente Pineda, located at Oroquieta, Felix Huertas, M. Natividad, and M. Hizon Streets in Santa Cruz, Manila. The total area of the land was 5,593 square meters, which was occupied by approximately fifty-seven tenants. The government's intention was to subdivide the land into smaller lots for resale to these tenants. During the proceedings, it was discovered that Leon Samia had transferred portions of his land to his three married children, prompting the inclusion of these individuals and their spouses as additional defendants. The court set a provisional value of P6,769 for the properties and ordered the sheriff to place the plaintiff in possession after the required monetary deposit was made. The defendants contended that the lands were small lots and thus not subject to expropriation under Commonwealth Act No. 539, leading to several motions to dismiss, which the court deferred. The defendants later sought damages in the form of unpaid rentals from the plaintiff and the tenants, which the court allowed. On March 12, 1948, the defendants requested to withdraw P3,700 from the deposit for back rentals, which the court partially granted, allowing a withdrawal of P3,000. As the case progressed, the defendants reiterated their motion to dismiss based on a recent Supreme Cour...