G.R. No. L-24661, L-24915, L-24916 February 28, 1974
BENJAMIN RABUCO, ET AL. vs. HON. RAMON BAGATSING, ET AL.

FACTS

The petitioners are numerous bona fide occupants and tenants of a parcel of land in San Andres, Malate, Manila. The land, although titled in the name of the City of Manila, was declared by Republic Act No. 3120 (enacted June 17, 1961) to be communal land of the State. The Act mandated its subdivision and the sale of the resulting lots on installment to the said occupants. The City of Manila, through its officials, initiated ejectment proceedings and secured orders for the demolition of the petitioners’ houses, contending the structures violated city ordinances and constituted public nuisances. The petitioners sought to enjoin these actions, arguing that R.A. 3120 expressly prohibited their ejectment and demolition, and they filed a mandamus to compel the Land Authority (now Department of Agrarian Reform) to implement the law’s provisions for subdivision and sale.
The trial court dismissed the petitioners’ suit, sidestepping the constitutional challenge to R.A. 3120 and ruling that the demolition could proceed as an abatement of a public nuisance regardless of ownership. The Court of Appeals, where the petitioners appealed and also filed an independent injunction petition, found the constitutionality of R.A. 3120 to be the dominant and inextricable issue, over which it had no jurisdiction. It therefore certified the consolidated cases to the Supreme Court for final determination.

ISSUE

Whether Republic Act No. 3120 is constitutional, particularly as to whether it constitutes a taking of private property without just compensation or violates due process by depriving the City of Manila of its property.

RULING

The Supreme Court upheld the constitutionality of Republic Act No. 3120 . The legal logic rests on the nature of the property involved and the scope of legislative power over state assets. The Court ruled that the land, although registered in the name of the City of Manila, was correctly classified by Congress as communal land of the State. As such, it is property of the public domain over which the National Government retains ultimate control and power of disposition.
The enactment of R.A. 3120 did not constitute an exercise of eminent domain requiring just compensation. Instead, it was a valid exercise of Congress’s plenary power to administer and dispose of state property. The law merely confirmed the land’s character as state property and provided the mechanism for its distribution to its landless occupants in line with the social justice principles of the Constitution. The subdivision and sale to the bona fide occupants were manifestations of the legislature’s right to deal with state property, not an expropriation of municipal assets. Consequently, the City of Manila’s claim of deprivation was unfounded, as it never held absolute or private ownership but merely held the land in trust for a public purpose which Congress could alter or supersede. The respondents were thus ordered to desist from ejecting the petitioners and to implement the law.