G.R. No. L-62157 - Mora, Jr. vs. Employees' Compensation Commission

Petitioner: Samahan ng Masang Pilipino sa Makati, Inc. (SMPMI), represented by Chairman Robert L. Mora, Sr.
Respondents:

Bases Conversion Development Authority (BCDA), represented by BCDA Chairman Rogelio Singson.
Municipality of Taguig, represented by Mayor Ricardo D. Papa.

SMPMI filed a petition for a Temporary Restraining Order (TRO) and injunction to halt the planned eviction of its members from their homes.
The petition sought to prevent BCDA from executing eviction notices based on Section 21 of Republic Act (RA) 7227, which grants the Supreme Court jurisdiction to issue injunctions against BCDA.

The disputed property consists of portions of Fort Bonifacio occupied by petitioners’ members, specifically Lots 1, 3, and 4, with an aggregate area of 97.58 hectares.
Petitioners allege that the lots are under the ownership of the United States of America as evidenced by Transfer Certificate of Title (TCT) No. 2288, and therefore should not be subject to forcible eviction by BCDA.

RA 7227 (Bases Conversion and Development Act of 1992) empowers BCDA and outlines the conversion of military reservations, including Fort Bonifacio, for alternative productive uses.
Executive Order (EO) No. 40, series of 1992, identified specific portions of Metro Manila military camps (including Fort Bonifacio) for development and disposition to generate funds for BCDA projects.
Special patents (Special Patent Nos. 3610 and 3596) were issued to formalize BCDA’s claim over designated lots within Fort Bonifacio.
Petitioners also underscore alleged deficiencies in the technical descriptions and tie-lines provided in the legislation, which they claim weaken BCDA’s legal claim.

SMPMI contends that its members have been occupying the disputed lots peacefully and continuously, thus establishing a right to remain undisturbed.
They argue that the eviction notices from BCDA and the Municipality of Taguig are illegal since the land, they claim, remains under USA ownership and lacks proper technical delineation.
BCDA counters that, under RA 7227 and EO No. 40, title and authority over Fort Bonifacio have been lawfully transferred from the USA to the Philippine Government and then to BCDA.
BCDA further argues that SMPMI is not the proper party in interest because its members have not demonstrated any legal title or ownership of the disputed lots.

The controversy is compounded by prior proceedings, such as the case before COSLAP (Commission on Settlement of Land Problems), raising issues of forum-shopping by SMPMI.
Other legislative measures, notably RA 7279 (the Urban Development and Housing Act known as the Lina Law), were discussed to assess whether petitioners are entitled to housing protection; however, the court found that the petitioners’ occupants are considered professional squatters with sufficient financial means.
An incident involving demolition on April 27, 2000, and subsequent investigations by the Office of the Deputy Ombudsman for the Military confirmed that the eviction and demolition were conducted under valid legal authority and in response to violent resistance.

Whether petitioners have a cause of action against the respondents given that they failed to show a clear legal right or interest in the property.
Whether BCDA has a lawful and valid claim over the property owing to its statutory authority under RA 7227 and the issuance of proper titles after cancellation of the USA’s TCT.
Whether the petitioner is guilty of forum-shopping by engaging in parallel or collateral proceedings on the same issue.
Whether the petition amounts to a collateral attack on the previously determined titles and ownership of the disputed lots.

Whether BCDA (through RA 7227) can legally appropriate any portion of Fort Bonifacio without clear tie-lines or technical descriptions to delimit its claim.
Whether BCDA and the Municipality of Taguig can, through extrajudicial means, evict the members of SMPMI without providing the protections required under PD 1576 (Lina Law).
Whether BCDA can proceed with eviction without offering an alternative homesite as mandated by the law.
Whether the Supreme Court is authorized to issue a TRO to prevent potential violence pending the resolution of the controversy.