G.R. No. L-17569. May 31, 1963.
REPUBLIC OF THE PHILIPPINES (Represented by the Land Tenure Administration), plaintiff-appellant, vs. MANUEL SAMIA, ET AL., defendants-appellees.

FACTS

The Republic, through the Land Tenure Administration, filed a complaint on July 18, 1957, to expropriate 21 parcels of land on Pingkian Street, Tondo, Manila, owned by the Samia family, pursuant to Republic Act No. 1162 . An amended complaint dated May 29, 1959, added 10 more parcels at the corner of Jose Abad Santos Avenue and Bambang Street, owned by the minor children of some defendants. The total subject of the expropriation thus became 31 separate parcels with a combined area of 38,279.30 square meters, owned by 14 individuals and located in two distinct areas of Manila. The defendants filed a motion to dismiss.
The trial court granted the motion and dismissed the case, ruling the plaintiff had no right to expropriate. The plaintiff appealed, arguing the court should have allowed it to complete its evidence instead of dismissing the case outright based on the motion. The Court of Appeals certified the case to the Supreme Court due to the value of the properties exceeding P200,000.

ISSUE

Whether the trial court correctly dismissed the expropriation complaint for failure to state a valid cause of action under Republic Act No. 1162 , as amended.

RULING

Yes, the dismissal was proper. The Supreme Court affirmed the trial court’s order. The Court first addressed the procedural objection, holding that nothing in the Rules prohibits the filing or granting of a motion to dismiss in expropriation proceedings if the complaint, on its face, reveals no valid cause of action, thereby allowing for prompt disposition.
On the substantive merits, the expropriation was not authorized by law. The action was initially based on RA 1162 as amended by RA 1990 (effective June 1957), which only authorized the expropriation of “landed estates or haciendas” in Manila, Quezon City, and suburbs. The plaintiff attempted to aggregate 31 separate lots owned by 14 different persons to form a supposed “landed estate.” The Court rejected this, citing its prior ruling in Republic v. Samia (89 Phil. 483), which held it unfair to combine small, separately owned contiguous lots to artificially create a large estate subject to condemnation. The biggest single aggregation owned by one defendant (Manuel Samia) was only 6,614.50 square meters, which could not be considered a landed estate.
The plaintiff also invoked the later amendment, RA 2342 (effective June 1959), which authorized expropriation of “any piece of land” meeting specific conditions (leased for ten years with at least fifty tenant houses). The Court held this law could not apply retroactively to this case, as it affects substantive rights. Furthermore, even assuming its application, the properties still failed to meet the law’s requirements. The largest aggregation of lots could not physically accommodate fifty houses, given the statutory planning guidelines, and the trial court found that none of the individual defendant’s lots had more than fifty bona fide tenants with houses erected for over ten years. Therefore, the complaint failed to state a cause of action under any applicable version of the law.