Case Summary (G.R. No. 221366)
RTC’s Exercise of Eminent Domain
The RTC granted the complaint, finding that ordinance, public purpose, negotiation, and deposit requisites were met. It dispensed with RA 7279’s priority list, accepting the City’s unsubstantiated claim that on-site development of private lands was most practicable for beneficiaries who had occupied the lots for decades.
CA’s Reversal on Strict Compliance
The Court of Appeals emphasized the onerous impact of eminent domain on private property. It held that the City failed to:
- Demonstrate evidence that the lots qualified as blighted areas under RA 7279 for on-site development;
- Exhaust prior acquisition modes before expropriation, as mandated by RA 7279 Section 10;
- Prove that intended beneficiaries were “underprivileged and homeless” under RA 7279 Section 8;
- Support its deviation from the statutory priority sequence in RA 7279 Section 9.
Accordingly, the CA reversed and set aside the RTC order.
Issue on Review
Whether the City of Manila complied with constitutional and statutory conditions for exercising delegated eminent-domain power, particularly under LGC Section 19 and RA 7279.
Supreme Court’s Ruling and Legal Standards
Applying the 1987 Constitution and relevant statutes, the Court reiterated that eminent domain by a local government is a delegated power subject to strict conditions:
• Valid ordinance authorizing expropriation;
• Public use or welfare, specifically benefit of the poor and landless;
• Prior definite offer in good faith;
• Payment of just compensation;
• Compliance with RA 7279’s priorities (Section 9) and exhaustion of other acquisition modes (Section 10).
Findings on Non-Compliance
The City failed to present any survey, study, or evidence showing:
• That the subject lots were blighted areas warranting on-site development;
• That lands higher in RA 7279’s priority list were considered or acquired first;
• That beneficiaries were truly underprivileged and home
Case Syllabus (G.R. No. 221366)
Procedural History
- Petitioner City of Manila sought a writ of possession and expropriation of certain parcels under Rule 67 of the Rules of Court in RTC-Manila, Branch 52 (Civil Case No. 04-110823).
- The RTC issued an expropriation order (June 23, 2011) after petitioner complied with deposit requirements.
- Respondents’ motions for reconsideration were denied by the RTC on January 22, 2013.
- Respondents appealed to the Court of Appeals (CA-G.R. CV No. 101440), which reversed and set aside the RTC order in a Decision dated June 30, 2015 and denied petitioner’s motion for reconsideration in a Resolution dated November 9, 2015.
- City of Manila filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.
Facts
- On January 19, 2004, Manila City Council enacted Ordinance No. 8070 authorizing the mayor to acquire specified lots owned by respondents under the “Land-For-The-Landless Program.”
- Petitioner’s initial negotiated offer of ₱2,000.00 per square meter was rejected by respondents who claimed their properties were worth more.
- On September 3, 2004, petitioner filed a complaint for expropriation and sought immediate possession, depositing ₱4,812,920.00 (over 100% of assessed value).
- RTC denied the writ of possession on February 2, 2005 for failure to deposit the additional ₱852,519.00 (15% fair market value per Local Government Code), which petitioner and prospective beneficiaries later satisfied (₱425,519.00 by petitioner; ₱443,621.00 by beneficiaries).
- A Writ of Possession was issued by the RTC on October 6, 2006.
Ruling of the Regional Trial Court
- All requisites for local government expropriation under Rule 67 and the Local Government Code were found satisfied.
- Ordinance No. 8070 constituted valid legislative authorization for public use (landless housing and on-site development).
- Petitioner made “definite and formal offers” which respondents refused.
- RTC dispensed with the statutory priority list in RA 7279, accepting petitioner’s assertion that on-site development of private land was most practicable and advantageous.
- Disposed: “An order of expropriation is hereby