G.R. No. L-57625 May 3, 1983
AVELINO PULIDO, ET AL., petitioners, vs. THE HONORABLE COURT OF APPEALS, ET AL., respondents.

FACTS

The President issued Letter of Instruction No. 1033 and subsequent Proclamations reserving approximately 276 hectares of land in Cavite for the establishment of the Cavite Export Processing Zone (CEPZ). The reserved area included both public and privately-owned lands, many of which were irrigated ricelands cultivated by petitioner farmers. The Export Processing Zone Authority (EPZA), tasked with implementing the project, enlisted provincial officials to advise farmers to cease planting due to the imminent government takeover. EPZA offered compensation to cultivators, which some accepted while others refused.
The farmers who refused, numbering seventy-six and represented by their association, filed a complaint before the Court of Agrarian Relations in Cavite. They sought to protect their alleged rights under agrarian reform laws and to prevent the conversion of their farmlands. They also obtained a temporary restraining order from the Court of Appeals. However, the appellate court later lifted this restraining order upon the posting of a bond by the defendants. The petitioners then filed this action for certiorari, prohibition, and mandamus to annul that resolution and to stop the land conversion pending the appeal.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in lifting the temporary restraining order against the conversion of the subject agricultural lands for the CEPZ project.

RULING

The Supreme Court dismissed the petition. The legal logic rests on two primary grounds: mootness and the political nature of the expropriation decision. First, the issue was rendered moot and academic because, subsequent to the filing of this petition, the government had initiated expropriation proceedings specifically for the land occupied by petitioner Avelino Pulido in the Court of First Instance. The court in that case had already issued an order for a writ of possession after the deposit of compensation. Therefore, any question regarding the propriety of the appellate court’s interlocutory order became inconsequential.
Second, and more fundamentally, the Court emphasized that the necessity and expediency of exercising eminent domain for a public purpose—such as establishing an export processing zone to promote economic progress—are questions of a political character, not judicial. The wisdom of the Presidential proclamations converting the agricultural land for industrial use is within the exclusive prerogative of the Executive branch. The judiciary may not inquire into or substitute its judgment for this determination. Any challenge to the necessity of the taking should be raised in the expropriation court itself, not through a collateral attack. While sympathetic to the displacement of farmers, the Court held that private interests must yield to the overarching public interest and the benefit of the greater majority.