G.R. No. L-33145 March 30, 1979
ELIGIO P. BUENAVENTE, ET AL., petitioners, vs. HON. ALEJANDRO MELCHOR, ET AL., respondents.

FACTS

The petitioners, thirty-three family heads, resided in houses erected on a riverbank portion of a lot owned by the National Development Corporation (NDC) in Manila. They filed a petition for Declaratory Relief and Prohibition with Preliminary Injunction in the Court of First Instance of Manila to prevent the threatened demolition of their houses and their relocation to Carmona, Cavite. This threat stemmed from a letter by the Presidential Assistant on Housing Resettlement Agency. The petitioners argued they should be declared first priority applicants for units in a nearby multi-storey tenement building constructed under Republic Act No. 3469, which authorized such projects for the poor.
Respondents, including government officials, countered that the petitioners were mere squatters on the NDC lot without any legal right to protection. They further asserted that the tenement building in question was only partially completed and its purpose had been abandoned, as the Office of the President had allocated the entire site for use as a school by the Philippine College of Commerce (PCC). The trial court dismissed the petition and dissolved a previously issued restraining order, prompting the petitioners to elevate the case via certiorari.

ISSUE

The primary issues were: (1) whether the petitioners were squatters without legal rights to protect; (2) whether they had a right to priority under Republic Act No. 3469; and (3) whether the President’s directive to use the uncompleted building for a school violated the said law.

RULING

The Supreme Court dismissed the petition. On the first issue, the Court held that the petitioners were indeed squatters or, at best, occupants by mere tolerance of the NDC. Their occupation, even if initially with the NDC’s knowledge, did not vest in them any legal right enforceable against the owner, especially when the owner demanded vacatur. The lot, owned by a government corporation, was considered public land in a broad sense, and the petitioners’ continued stay against the owner’s will conferred no protected legal interest.
Regarding Republic Act No. 3469, the Court ruled that the law merely authorized the construction and funding of tenement buildings; it did not prohibit the temporary use of an uncompleted building for another urgent public purpose. The President, vested with authority to approve implementing rules and regulations, acted within his discretion in allocating the still-uncompleted structure to the PCC for educational use. The priority scheme established under the law’s rules had not yet become operative, as the building was not completed or turned over for occupancy. Therefore, the petitioners acquired no vested right to the units. Their lack of a clear legal right meant they had no cause of action for declaratory relief or prohibition. The presidential directive served a greater public interest and was not a repeal of the law by executive action.