Case Summary (G.R. No. 187604)
Background of the Case
On March 1, 2001, the City Council of Manila enacted Ordinance 8012, empowering the City Mayor to acquire certain lots from the respondents for a socialized housing initiative. An offer of P1,500.00 per square meter was made, which was rejected by the property owners as insufficient. Consequently, on December 2, 2003, the City filed a complaint for expropriation in the Regional Trial Court (RTC) of Manila, asserting the need for these properties to facilitate on-site development programs for local residents.
Legal Proceedings and Initial Rulings
The City made an initial deposit of P1,500,000.00 with the Land Bank of the Philippines, seeking to occupy the lots pending judicial proceedings. Respondents challenged the expropriation, arguing that the City failed to prove the necessity for such action and did not genuinely engage in negotiations for a fair price. On June 9, 2004, the RTC issued a writ of possession in favor of the City. However, the RTC later dismissed the expropriation case on February 12, 2008, citing the City's non-compliance with the requirements under Sections 9 and 10 of Republic Act (R.A.) 7279, which governs expropriation processes for socialized housing.
Court of Appeals Decision
The Court of Appeals (CA) affirmed the RTC's dismissal, stating that the City did not demonstrate adherence to the statutory order of priorities for land acquisition. The CA rebuffed the City’s claims of being denied due process, emphasizing that the City waived its opportunity to present additional evidence when agreeing to a simultaneous submission of memoranda without further elaboration.
Issues Presented on Appeal
The issues raised in the petition included whether the CA erred in affirming the RTC's dismissal without adequate hearing of the City's side, failed to acknowledge the City's lack of compliance with expropriation requisites, and incorrectly ruled that the respondents' withdrawal of the deposit constituted implied consent to expropriation.
Court's Rulings
Right to be Heard: The Court ruled that there was no denial of the City's right to be heard since the case was in its initial stage, and the City’s decision to opt for a memorandum submission indicated a strategy that came with risks, including waiving its right to present affirmative evidence.
Failure to Follow Statutory Requirements: The CA correctly found that the City neglected to comply with the priorities set forth in Section 9 of R.A. 7279 for land acquisition. The City failed to present evidence supporting that the acquisition of the private lots was justified, nor did it effectively utilize negotiation avenues prior to resorting to expropriation.
Genuine Necessity of Expropriation: The City also failed to establish the genuine necessity for expropriation, as it had not presented evidence that the taking of the properties served a public use or purpose, especially when challenged by the respondents.
Withdrawal of Deposit and Im
Case Syllabus (G.R. No. 187604)
Case Overview
- This case revolves around the legal issues a local government unit faces when attempting to expropriate private property for socialized housing.
- The City of Manila sought to acquire properties owned by Alegar Corporation, Terocel Realty Corporation, and Filomena Vda. De Legarda for a housing project.
Legislative Background
- On March 1, 2001, the City Council of Manila passed Ordinance 8012, which authorized the City Mayor to acquire certain lots for socialized housing.
- The City initially offered P1,500.00 per square meter for the properties, which was rejected by the owners.
- The City subsequently filed a complaint for expropriation on December 2, 2003, citing the need for the land for its land-for-the-landless and on-site development programs.
Expropriation Proceedings
- The total assessed value of the properties for taxation was P809,280.00, while the City deposited P1,500,000.00 with the Land Bank of the Philippines for immediate occupancy pending the case hearing.
- Alegar Corporation and Terocel Realty Corporation questioned the legitimacy of the expropriation, arguing the property was being taken for the benefit of a few occupants and that the City had not engaged in good faith negotiations.
Trial Court Proceedings
- On June 9, 2004, the Regional Trial Court (RTC) issued a writ of possession in favor of the City.
- By December 19, 2006, the RTC released the P1,500,000.00 deposit to the defendants upon a joint motion.
- The parties agreed to submit memoranda on the issue of necessity for expropriation instead of proce