G.R. No. L-34669 December 15, 1982
CITIZENS’ SURETY AND INSURANCE CO., INC., petitioner, vs. THE HON. JUDGE RICARDO C. PUNO, THE REGISTER OF DEEDS OF THE CITY OF MANILA AND THE CITY OF MANILA, respondents.

FACTS

Maria Barcelon owned a lot in Barrio Obrero, Tondo, Manila, originally acquired from the city. The sale of such lots was governed by Manila City Resolution No. 542, series of 1956, which implemented the city’s charter by limiting purchasers to Filipino laborers who were bona fide Manila residents earning not more than P180.00 per month. Barcelon mortgaged the land to petitioner Citizens’ Surety and Insurance Co., Inc. Upon foreclosure and after the redemption period, the petitioner, as the purchaser, sought to consolidate its ownership.
The Register of Deeds of Manila refused to register the affidavit of consolidation, citing Resolution No. 542. Petitioner then filed a case seeking to declare the resolution null and void and to compel its registration. The Court of First Instance, through Judge Ricardo C. Puno, dismissed the case, prompting this appeal by certiorari.

ISSUE

The core issues are: (1) Whether Resolution No. 542 is unconstitutional for violating the equal protection clause by limiting buyers to “laborers” and excluding other low-income groups; and (2) Whether the resolution applies to forced sales such as foreclosure sales.

RULING

The Supreme Court dismissed the petition, upholding the constitutionality of Resolution No. 542 and its applicability to forced sales. On the constitutional challenge, the Court found the classification limiting buyers to “laborers” (obreros) to be reasonable and germane to the purpose of the law. The lot was situated in “Barrio Obrero,” and the city charter authorized the sale of such acquired lands to residents, giving priority to tenants, laborers, and low-salaried employees. The resolution was a valid implementation of this charter mandate. The classification rests on a substantial distinction relevant to the law’s objective of providing homes to a specific disadvantaged class as identified by the legislative body, and the Court found no manifest abuse of discretion in the city’s judgment.
Furthermore, the petitioner, a corporation, lacked standing to raise the claim that the resolution was unreasonable for excluding non-laborers with similarly low incomes, as it would not benefit from a ruling in its favor since it was not a lowly paid worker. Regarding the second issue, the Court affirmed that the resolution applies to forced sales. Its legal intent would be utterly nugatory if restricted to voluntary sales, and since the text does not distinguish between voluntary and forced sales, no such distinction should be made.