G.R. No. L-37399 - Uy vs. Genato

Petitioners, owners of residential lots in the City of Oroquieta, alleged that a portion of their properties, previously reserved as “road-right-of-way,” was taken after the city undertook a road-widening project.
The City Engineer, acting for the City of Oroquieta, implemented the widening of roads which resulted in the taking of the petitioners’ property.
Petitioners sought:

Payment of just compensation for the part of their property taken.
Reimbursement for expenses incurred due to the removal or demolition of improvements on their lots.

On March 27, 1973, following the effectivity of the present Constitution, petitioners filed a complaint alleging the taking and the failure to award just compensation.
Defendants, namely the City of Oroquieta and its City Engineer, moved to dismiss the complaint on the ground of lack of jurisdiction.

The dismissal was based on the contention that the expropriation was undertaken pursuant to instructions emanating from the Commissioner of Public Highways and the Regional Director.
Such instructions were connected with martial law, implying that the taking was carried out under executive direction beyond the purview of judicial interference.

The respondent Judge, Melecio A. Genato, initially denied the motion to dismiss, relying on a presidential decree (Presidential Decree No. 42) which underscored the constitutional requirement for just compensation.
However, on June 21, 1973, the respondent Judge reversed his earlier position:

He granted the motion to dismiss, asserting that since the expropriation was traceable to a presidential letter of instruction (Letter of Instruction No. 43) issued during martial law, the matter fell outside his jurisdiction.
A motion for reconsideration was subsequently filed and denied, prompting petitioners to seek certiorari with the Supreme Court.

Petitioners emphasized their constitutional right to due process under Article IV, Sec. 1 of the Constitution, which requires that no person be deprived of property without proper legal procedure.
They also cited Article IV, Sec. 2 of the Constitution mandating that private property shall not be taken for public use without just compensation.
The petitioners relied on precedents (Herrera vs. Auditor General, Alfonso vs. Pasay City, and Ministerio vs. Court of First Instance of Cebu) where similar expropriations, even absent formal condemnation proceedings, were ultimately followed by the payment of just compensation.

The respondent Judge’s dismissal was primarily based on the argument that the expropriation, being linked to martial law directives and executed pursuant to a presidential letter, lay beyond the scope of judicial inquiry.
Petitioners contended that such reasoning was erroneous and misapplied because:

The presidential decree demonstrated an adherence to the constitutional requirement for just compensation.
The existence of a letter of instruction did not negate the mandate that property taken for public use must be compensated.

They argued that the denial of a hearing deprived them of their constitutional right to present evidence regarding their claim for just compensation.

Whether the lower court’s dismissal of the petitioners’ complaint, on the ground that the expropriation was carried out pursuant to martial law instructions, was proper.
Whether the invocation of a presidential letter of instruction, issued during the period of martial law, legally provides a basis to curtail judicial jurisdiction in adjudicating the petitioners’ claim to just compensation.

Whether the denial of a hearing to allow the petitioners to substantiate their claim for just compensation violated their constitutional right to due process.
Whether judicial timidity, in light of explicit constitutional guarantees, is permissible when faced with executive actions even if such actions are purportedly taken under martial law provisions.

Whether the enforcement of a presidential decree, which seemingly complies with the constitutional mandate on just compensation, conflicts with or overrides the judicial function.
Whether instructions emanating from the highest executive authority under martial law can exempt subordinate officials from the obligation to follow constitutional due process in property expropriation cases.