Case Summary (G.R. No. 211363)
Case Background
The petitioners occupied various portions of public streets and waterways in Manila during the late 1940s and early 1950s. Notably, they built houses on Calabash Road, Antipolo and Algeciras Streets, R. Papa Extension, as well as on riverbeds and public waterways, often paying "concession fees" without prejudice to future orders requiring them to vacate the premises. The City Engineer issued notices demanding their removal in 1952, warning of imminent demolition if they failed to comply.
Legal Proceedings
The petitioners sought injunctive relief in response to threats of demolition. The Court of First Instance of Manila ruled against them, determining that their houses constituted public nuisances under existing city ordinances and the Civil Code of the Philippines. The lower court decisions were appealed directly to the Supreme Court, which consolidated the cases due to the similar factual background and legal questions.
Nuisance Law Application
The lower court characterized the unauthorized structures as public nuisances according to Article 694 of the Civil Code, stating that such nuisances obstruct public access and may cause harm or annoyance to the community. The Supreme Court agreed with this assessment, noting that the structures interfered with public use and enjoyment of the streets and waterways.
Authority of City Engineer and Legal Justifications
The Court discussed the roles of the City Engineer vis-Ã -vis the district health officer under Articles 700 and 702 of the Civil Code, ultimately affirming that the City Engineer held the authority to abate public nuisances under Section 31 of Republic Act No. 409, which is specific to the City of Manila. Thus, despite the general provisions regarding nuisances, the Court recognized the special legislative powers granted to local authorities to manage public spaces.
Due Process Concerns
The petitioners argued that demolitions attempted without a formal hearing constituted a violation of their right to due process. However, the Court emphasized that their respective buildings were established without legal authority on public property, which legitimized the summary removal under the police power
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Case Overview
- The case involves six class suits filed against Alejo Aquino, the City Engineer of Manila, by various petitioners who sought to prevent the demolition of their houses, which were claimed to be public nuisances.
- The cases were consolidated for hearing due to similar facts and legal issues, with each case being heard under separate case numbers by the Court of First Instance of Manila.
- The petitioners consisted of individuals who constructed houses on public streets and waterways without proper authority and had been warned about the impending demolition.
Factual Background
- Case No. L-8191: Petitioners occupied portions of Calabash Road in Manila and constructed houses without consent. After receiving notices to vacate, they were informed they would face demolition if they did not comply.
- Case No. L-8397: Petitioners occupied portions of Antipolo and Algeciras Streets, obstructing roads and drainage systems. Similar to the previous case, they received notice to vacate and faced threats of demolition.
- Case No. L-8500: Petitioners occupied R. Papa Extension without authority. They were also warned about the demolition of their homes after failing to vacate.
- Case No. L-8513: Occupants built houses on the bed of a branch of Estero de San Miguel, facing similar notices and threats regarding demolition.
- Case No. L-8516: Petitioners constructed homes on the Pasig River's bed, again receiving warnings for removal.
- Case No. L-86