G.R. No. L-49439 June 29, 1983
NATIONAL HOUSING AUTHORITY, petitioner, vs. HONORABLE PASTOR P. REYES, in his capacity as Presiding Judge (on detail), Court of Agrarian Relations, Seventh Regional District, Branch II, Cavite City, QUIRINO AUSTRIA and LUCIANO AUSTRIA, respondents.

FACTS

The National Housing Authority (NHA) filed a complaint for the expropriation of a 25,000-square-meter parcel of land owned by respondent Quirino Austria, needed for the expansion of the Dasmariñas Resettlement Project pursuant to Presidential Decree No. 757. The NHA deposited P6,600.00, equivalent to the property’s tax-assessed value, to secure a writ of possession. Subsequently, Austria moved to withdraw this deposit. The NHA opposed, citing Section 92 of P.D. No. 464, which provides that just compensation in government expropriation shall not exceed the market value declared by the owner or the assessor’s market value, whichever is lower. The NHA submitted that Austria’s own declared value for tax purposes was only P1,400.00, which was lower than the assessor’s valuation, and thus constituted the proper just compensation, precluding withdrawal of the larger deposit.
Respondent Judge Pastor P. Reyes issued an order on July 13, 1978, which the NHA contended was contrary to the cited decrees. The NHA’s motion for reconsideration, invoking the identical provision in P.D. No. 1224, was denied. The NHA thus filed this petition for certiorari, arguing the respondent judge acted without or in excess of jurisdiction by disregarding the clear mandate of the applicable presidential decrees.

ISSUE

Whether the respondent judge committed grave abuse of discretion amounting to lack or excess of jurisdiction in issuing orders that disregarded the explicit formula for determining just compensation under the relevant presidential decrees.

RULING

Yes. The Supreme Court granted the petition for certiorari. The legal logic is anchored on two fundamental principles. First, there is a presumption of validity accorded to legislative and executive acts. In this case, the validity of the presidential decrees (P.D. Nos. 76, 464, 1224) establishing the “whichever is lower” rule for determining just compensation was never challenged by the respondents in their comments. Absent any constitutional challenge, the Court must apply the law as it stands. The decrees speak in clear and unequivocal language, leaving the judiciary no choice but to yield to their command. When the law is unambiguous, it must be obeyed.
Second, the Court emphasized the rationale behind the decrees, which is to promote social justice and rationality in expropriation. The rule discourages the deceitful practice of property owners under-declaring values for taxation to avoid higher taxes, but then inflating them when the government acquires the property for public use. This practice is ruinous to government coffers and undermines public programs. The decrees do not violate the constitutional requirement of just compensation, as the owner himself is allowed to set the valuation through his own declaration for tax purposes. Therefore, the respondent judge’s order, which contravened this statutory formula, constituted a grave abuse of discretion. The order was nullified and set aside, and the case was remanded to the lower court for proceedings conformable to the decrees.