Title
Republic vs. Vda. de Caliwan
Case
G.R. No. L-16927
Decision Date
May 31, 1961
The Supreme Court rules that illegal occupants or "squatters" cannot benefit from expropriation laws, affirming the lower court's decision to order Gorgonia Vda. de Caliwan to vacate the lot she unlawfully entered and constructed a makeshift house on.
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Case Digest (G.R. No. L-16927)

Facts:

  • The case involves the interpretation of a law on expropriation of landed estates in Manila.
  • The Republic of the Philippines, represented by the Land Tenure Administration, acquired the property known as Fabie Estate in Paco, Manila through expropriation.
  • The Administration conducted a survey of the property and identified the occupants and tenants.
  • Lot 10, Block 41, was found to be vacant and unoccupied.
  • Perfecto Magaway, a tenant whose house was within a road lot, was allocated Lot No. 10, Block 41.
  • Gorgonia Vda. de Caliwan had entered the lot without permission and constructed a makeshift house.
  • The Administration demanded that Caliwan vacate the premises, but she refused.
  • The Administration filed ejectment proceedings against Caliwan, and the court ordered her to vacate the lot.
  • Caliwan appealed the decision to the Court of Appeals, which certified the appeal to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the lower court's decision and ruled that illegal occupants or "squatters" cann...(Unlock)

Ratio:

  • The Court based its decision on the interpretation of the word "occupant" in the law on expropriation.
  • The Court held that the word "occupant" refers to lawful occupants and tenants, or those with legitimate tenure.
  • The purpose of expropriation laws is to aid and benefit these lawful occupants and tenants by making their occupancy permanent and giving them an opportunity to become owners of their holdings.
  • The Court cited previous rulings that persons guilty of illegal entry cannot benefit from expropriation laws.
  • The Court emphasized that these laws are not meant for the benefit of the lawless.
  • The Court rejected the argument that squatters should also be considered beneficiarie...continue reading

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