GR L 14111; (October, 1960) (Digest)
G.R. No. L-14111; October 24, 1960
NATIONAL RESETTLEMENT AND REHABILITATION ADMINISTRATION, plaintiff-appellant, vs. TERESA R. DE FRANCISCO, ET AL., defendants-appellees.
FACTS
On June 11, 1955, Republic Act No. 1266 took effect, authorizing the National Resettlement and Rehabilitation Administration (NARRA) to expropriate the Hacienda del Rosario in Cabanatuan City within six months for subdivision and resale to bona-fide occupants. Pursuant to this law, NARRA instituted eminent domain proceedings against the heirs of the original owner, Judge Simplicio del Rosario (who died in 1947), and their subsequent vendees, covering approximately 669 hectares. During the proceedings, several heirs and defendants (Dolores R. Concepcion, Teresa R. de Francisco, Paz R. de Tubangui, and spouses Carmen R. de Ciocon and Jaime Ciocon) agreed to the expropriation of their holdings, voluntarily ceding about 3891.7583 hectares to NARRA. The case continued against the remaining defendants, who were purchasers and sub-acquirers of various portions of the hacienda, with holdings ranging from one-half to thirteen hectares, all acquired between 1949 and 1954 (before the passage of R.A. No. 1266 ). The defendants-spouses Ciocon also contested the expropriation of a specific 85.0414-hectare portion they wished to reserve for their family. The Court of First Instance of Nueva Ecija dismissed the condemnation proceedings against the remaining defendants, ruling that the subdivided lots were no longer part of the Hacienda del Rosario and were not the “big landed estate” subject to expropriation under the Constitution. NARRA appealed.
ISSUE
Whether NARRA has the authority under Republic Act No. 1266 and Article XIII, Section 4 of the Constitution to expropriate the subdivided portions of the original Hacienda del Rosario that are now held by the remaining defendants.
RULING
The Supreme Court affirmed the dismissal of the condemnation proceedings. The power of expropriation under R.A. No. 1266 is predicated on Article XIII, Section 4 of the Constitution , which authorizes the expropriation of lands to be subdivided into small lots and conveyed at cost. The Court applied its established rulings in Republic vs. Baylosis and Rural Progress Administration vs. Guido, which hold that under this constitutional provision, the government may only expropriate landed estates with extensive areas. Once such an estate has been broken up and divided into parcels of reasonable extent, the resulting portions are no longer subject to further expropriation. The Court found that the original Hacienda del Rosario had already been subdivided, and the sizes of the portions held by the remaining defendants were reasonable and uncontested. Therefore, these parcels could not be considered a “big landed estate” subject to expropriation. The Court also noted that NARRA had already acquired almost two-thirds of the original hacienda, and the trial court found that the tenant families intended to be benefited could be easily accommodated in the area already acquired. The Court rejected NARRA’s argument based on City of Manila vs. Chinese Community, distinguishing that the issue here was not the necessity of the expropriation but the constitutional authority to expropriate, which is a judicial question. The appeal was dismissed, with costs against NARRA.
