Case Summary (G.R. No. 217656)
Procedural Timeline
On September 13, 2010, Eddie Manalo, et al. filed their Complaint in the Regional Trial Court of Quezon City, seeking fair compensation for their properties. A Notice of Demolition issued by the Quezon City Task Force Control and Prevention of Illegal Structures occurred shortly after on November 15, 2010. The DPWH filed an Answer against the Complaint on January 19, 2011, which led to arguments about the status of the respondents as informal settlers and their rights. The Regional Trial Court ruled on May 5, 2011, denying DPWH's motion to dismiss the case. An appeal followed, leading to a Decision by the Court of Appeals on March 19, 2015, which was subsequently reviewed by the Supreme Court on November 16, 2020.
Legal Framework
The applicable constitutional provision is Article XIII, Section 10 of the 1987 Philippine Constitution, affirming that urban or rural poor dwellers shall not be evicted nor have their dwellings demolished without adherence to legal and humane processes. This provision was emphasized along with relevant laws, namely Republic Act No. 7279 (Urban Development and Housing Act) and Republic Act No. 8974, whereby rights related to expropriation and just compensation for those affected by government projects are outlined.
Findings of the Lower Courts
The Regional Trial Court found that the Complaint stated a valid cause of action, which was affirmed by the Court of Appeals. The courts recognized the foundational right of respondents to seek compensation due to the anticipated eviction and demolition of their homes. Importantly, they established that simply being informal settlers does not negate the respondents' rights to due process and just compensation.
Just Compensation and Due Process
The Supreme Court acknowledged the fundamental principles of just compensation as outlined in Article III, Section 9 of the Constitution while distinguishing respondents’ claims based on their status as informal settlers. While the DPWH maintains that respondents are professional squatters subject to summary eviction, the Court noted that the due process protections apply universally, necessitating compliance with procedural requirements for eviction or demolition as specified in the Urban Development and Housing Act and its implementing laws.
Petitioner's Contentions
The DPWH argued that the respondents, claiming the title of informal settlers, were not entitled to full just compensation but only to financial assistance. They pointed out an alleged failure of the respondents to assert valid claims based on their status. The DPWH maintained that the trial court erred in relying on a Memorandum of Agreement regarding other informal settlers, which supposedly indicated that the responsibility for providing equivalent assistance fell to the local government rather than the DPWH.
Court’s Conclusion on Compensation
The Supreme Court ruled that the DPWH’s conduct—including the solicitation of the respondents' relocation—acknowledged the respondents’ rights had been compromised. Despite claims of being professional squatters,
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Case Overview
- The case involves a Petition for Review on Certiorari filed by the Department of Public Works and Highways (DPWH) against Eddie Manalo and several others (collectively referred to as "respondents") regarding their complaint for just compensation due to the construction of the C-5 extension project in Quezon City.
- The primary legal issue revolves around the rights of informal settlers affected by government infrastructure projects and the obligations of the government regarding expropriation and compensation.
Parties Involved
- Petitioner: Department of Public Works and Highways (DPWH)
- Respondents: Eddie Manalo, Rodrigo Medianista, Cristan A. Acosta, Teresita D. Santos, Archemedis Sarmiento, among others, collectively owning residential structures on Luzon Avenue, Quezon City.
Background of the Case
- Respondents are owners of residential structures on a parcel of land owned by the Metropolitan Waterworks and Sewerage System, which is directly affected by the DPWH's C-5 extension project.
- On September 13, 2010, respondents filed a complaint in the Regional Trial Court (RTC) of Quezon City seeking just compensation, alleging that DPWH failed to initiate proper expropriation proceedings.
- Respondents asserted that DPWH made a "notoriously small" voluntary financial assistance offer, which they rejected, and they demanded compensation equivalent to the replacement costs of their houses.
Procedural History
- The RTC denied DPWH's motion to dismiss the complaint, leadi