GR L 2089; (October, 1949) (Digest)
G.R. No. L-2089; October 31, 1949
JUSTA G. GUIDO, petitioner, vs. RURAL PROGRESS ADMINISTRATION, respondent.
FACTS
The Rural Progress Administration (RPA) initiated expropriation proceedings against petitioner Justa G. Guido’s two adjoining lots in Maypajo, Caloocan, Rizal, with a combined area of 22,655 square meters. The land was partly commercial and located just outside Manila’s boundary on a main thoroughfare. Guido filed a petition for prohibition to prevent the expropriation, raising four grounds, including that the land was commercial and thus excluded from the coverage of Commonwealth Act No. 539 , which authorized the expropriation.
ISSUE
Whether Commonwealth Act No. 539 authorizes the expropriation of commercial land for resale to private individuals.
RULING
No. The Supreme Court granted the petition for prohibition. The Court held that Commonwealth Act No. 539 , enacted pursuant to Section 4, Article XIII of the 1935 Constitution, only authorizes the expropriation of private agricultural lands, particularly large estates or haciendas, for subdivision and resale to their tenants or occupants to address agrarian conflicts and social unrest. The constitutional provision and the implementing law were intended to break up existing large agricultural estates, not to authorize the government to expropriate any private land, especially commercial property, for resale to other private individuals. Expropriating commercial land for private use would violate the constitutional guarantees that private property shall not be taken without due process of law and not for public use without just compensation. The Court emphasized that the expropriation power under Act No. 539 must be construed restrictively and cannot be extended to commercial urban properties.
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