Case Summary (G.R. No. L-58058)
Applicable Law
The relevant laws include Presidential Decree No. 1472, which empowers the National Housing Authority to summarily eject squatters, and Presidential Decree No. 1261, which appoints the National Housing Authority as the administrator of the Tatalon Estate Housing Project. The 1987 Philippine Constitution serves as the constitutional framework for this decision, governing due process in the context of property rights.
Background of Ownership Claims
The petitioners claim ownership over specific portions of land within the Tatalon Estate, with various documents supporting their claims. Santiago Mendoza's claim relates to an 8.5-hectare lot obtained via an agreement from the DEUDORS in 1969. Carmen and Manuela Urbano assert title to a 1,500 square meter plot acquired in 1951. The de Guzman family claims a 1,700 square meter lot inherited from their father Serafin de Guzman, which also traces back to Tomasa F. de Salanga in 1949.
Expropriation Proceedings
In 1959, Republic Act No. 2616 authorized the expropriation of the Tatalon Estate, leading to administrative actions by the Land Tenure Administration aimed at subdividing and reselling it to bona fide occupants. Litigation ensued regarding the constitutionality of this act, resulting in the courts eventually recognizing the validity of the expropriation processes.
Presidential Decrees and Agreements
By 1978, the Tatalon estate was expropriated under a compromise agreement, determining just compensation and mandating the National Housing Authority to facilitate its administration. This agreement included provisions that allowed the government to allocate the land to eligible occupants, further solidifying state ownership over the estate.
Summary Ejection Authority
Presidential Decree No. 1472, issued in June 1978, authorized the National Housing Authority to eject squatters and unauthorized occupants from government projects without judicial orders, as long as proper notice was provided. This law reflects the government's strategy to manage and streamline housing projects, particularly under encumbered circumstances.
Petitioner Demands and Rejections
In communications between the petitioners and the National Housing Authority, the latter consistently denied petitions from individuals such as Manuela Urbano and the de Guzman siblings for inclusion in the beneficiary list, confirming their status as squatters.
Constitutional Consideration and Due Process
The petitioners argued that enforcement actions against them breached their property rights under due process. However, the court found that the petitioners could not assert ownership over the land since it had already been expropriated by the government. The claim of being deprived of property without due process was countered by the fact that notices of ejectment had been issued, fulfilling the requisite legal protocol.
Conclusion on
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Case Overview
- Petitioners: Santiago Mendoza, Carmen Urbano, Manuela Urbano, Renato de Guzman, Raquel de Guzman, Rosette de Guzman, and Romeo de Guzman.
- Respondents: National Housing Authority and Angelito Lazaro.
- Action: Petition for prohibition and request for a writ of preliminary injunction and/or restraining order to prevent demolition of petitioners' houses in Barangay Tatalon, Quezon City, and to declare Presidential Decree No. 1472 unconstitutional.
- Date of Decision: January 30, 1982.
Background and Material Facts
- Property Claims:
- Santiago Mendoza claims ownership of an 8.5-hectare portion acquired from DEUDORS via an agreement dated December 4, 1969.
- Carmen and Manuela Urbano assert title over a 1,500 sq.m. lot through a contract dated May 4, 1951, from Tomasa F. de Salanga.
- Renato, Raquel, Rosette, and Romeo de Guzman inherited a 1,700 sq.m. portion from their father, Serafin de Guzman, who acquired it from Tomasa F. de Salanga on September 6, 1957.
- Legislative Actions:
- Republic Act No. 2616, enacted on August 3, 1959, authorized the expropriation of the Tatalon Estate for subdivision and resale to bona fide occupants.
- The J.M. Tuason and Co., Inc. contested the constitutionality of Republic Act No. 2616, which was initially upheld by the lower court but later reversed by the higher court.
Subsequent Legal Developments
- Presidential Directives:
- On October 27, 1972, the President directed the People's Homesite and Housing Corporation to acquire the Tatalon Estate, leading to a con