G.R. No. 106593 November 16, 1999
NATIONAL HOUSING AUTHORITY, petitioner, vs. HON. MAURO T. ALLARDE, Presiding Judge, RTC, Branch 123, Kalookan City and SPOUSES RUFINO AND JUANITA MATEO, respondents.

FACTS

The National Housing Authority (NHA) sought to develop Lots 836 and 839 of the Tala Estate in Kalookan City, which were reserved for housing and resettlement by Proclamation No. 843 in 1971. Private respondents, the Spouses Mateo, claimed to have occupied and farmed portions of these lots since 1928 and 1959, respectively. In 1992, the NHA began bulldozing the land for development. The spouses filed a complaint for damages with a prayer for a preliminary injunction before the Regional Trial Court, arguing the land was agricultural and covered by the Comprehensive Agrarian Reform Program (CARP), thus barring the NHA’s actions.
The RTC granted the injunction, finding the land to be agricultural and within CARP coverage. The NHA moved for reconsideration, contending the lots were non-agricultural lands reserved for housing and that the injunction violated P.D. No. 1818, which prohibits courts from issuing injunctions against government infrastructure projects. The RTC denied the motion. The NHA then filed this Petition for Certiorari directly with the Supreme Court.

ISSUE

The pivotal issues were: (1) whether the CARP covers government lands reserved for specific public purposes prior to its effectivity; and (2) whether housing and resettlement projects constitute “infrastructure projects” under P.D. No. 1818, thereby prohibiting the issuance of an injunction.

RULING

The Supreme Court granted the petition, setting aside the RTC’s orders and dissolving the writ of preliminary injunction. On the first issue, the Court ruled that lands already classified, reserved, or converted to non-agricultural uses by government agencies prior to the effectivity of the CARP in 1988 are excluded from its coverage. Citing Natalia Realty, Inc. v. Department of Agrarian Reform, the Court held that Proclamation No. 843, issued in 1971, effectively classified the Tala Estate, including the subject lots, as non-agricultural land intended for housing. Therefore, the CARP did not apply, and the spouses had no vested agrarian right to the land.
On the second issue, the Court ruled that housing and resettlement projects qualify as “infrastructure projects” under P.D. No. 1818. Citing Republic v. Silverio, the Court defined infrastructure projects broadly to include housing, which is vital for national development and social stability. P.D. No. 1818 expressly prohibits courts from issuing injunctions that delay or impede the implementation of such government projects. Consequently, the RTC gravely abused its discretion in issuing the injunction, as the spouses failed to show a clear legal right warranting protection against the NHA’s lawful implementation of a reserved public purpose. The Court emphasized the necessity of preventing disruptions to essential government projects.