GR 76182; (March, 1991) (Digest)
G.R. No. 76182 ; March 11, 1991
Pedro M. Belen, petitioner, vs. Court of Appeals and Alfredo Juliano and all the members of his family, respondents.
FACTS
Petitioner Pedro M. Belen was the lessee of a portion of land owned by Manotok Services, Inc. in Tondo, Manila. He built a house on the lot. Private respondent Alfredo Juliano and his family occupied a part of the same lot in 1978, after Juliano purchased a house standing thereon from another person. Belen and Juliano reached an agreement allowing Juliano to stay temporarily and share the rental. After a fire destroyed both houses, Belen permitted Juliano to remain for a maximum period of two and a half years. When Juliano failed to vacate after this period, Belen filed an ejectment suit in the Metropolitan Trial Court (MeTC), which ruled in his favor.
Juliano appealed to the Regional Trial Court (RTC), which reversed the MeTC. The RTC based its decision on Presidential Decree No. 1670, which expropriated the Manotok Estate, including the subject lot, for a housing project. The RTC held that upon the effectivity of the decree, Manotok’s ownership and Belen’s lease were terminated, and Juliano, as a certified prospective beneficiary of the National Housing Authority (NHA) project, could not be ejected by Belen. The Court of Appeals affirmed this decision.
ISSUE
Whether Presidential Decree No. 1670 validly expropriated the property and thereby extinguished Belen’s right as lessee to eject Juliano.
RULING
The Supreme Court reversed the decisions of the Court of Appeals and the RTC and reinstated the MeTC judgment. The Court held that PD 1670 was unconstitutional and void ab initio. The decree provided for a mode of fixing just compensation—based on the valuation determined by the City Assessor, considering conditions like the presence of squatters—that contravened the fundamental requirement of judicial determination in eminent domain proceedings. Following established jurisprudence, such legislative pre-determination of compensation, depriving the courts of their function, is invalid. Consequently, all acts done pursuant to the void decree, including the NHA’s taking of possession and its selection of beneficiaries, were also void. The invalidation of PD 1670 removed the sole legal basis for the appellate courts’ rulings. With the decree nullified, Manotok’s ownership and Belen’s subsisting lease remained effective. The Court found no error in the MeTC’s factual and legal conclusion recognizing Belen’s superior right of possession over the lot, thereby entitling him to eject Juliano.