G.R. No. L-6191 January 31, 1955
REPUBLIC OF THE PHILIPPINES, plaintiff-appellee, vs. CIRILO P. BAYLOSIS, ET AL., defendants-appellants.

FACTS

The Republic of the Philippines, through the Bureau of Lands, initiated expropriation proceedings for seven lots (with a total area between 67 and 77 hectares) that were formerly part of the Hacienda Lian or Lian Estate in Batangas, originally owned by Colegio de San Jose Inc. Nelson V. Sinclair was a lessee who purchased his leased portion in 1937 and later subdivided it. Sinclair sold several lots to Cirilo P. Baylosis between 1947 and 1950, who then subdivided and sold portions to his co-defendants. In October 1946, 68 persons claiming to be tenants and occupants petitioned the Rural Progress Administration (RPA) for the government to acquire the land for resale to them, citing unsatisfactory relations with Sinclair. The RPA corresponded with Sinclair and later Baylosis about the petition. The Republic filed a complaint for expropriation in 1951, later amended to include all subsequent buyers. The defendants filed motions to dismiss on several grounds, including that the expropriation was not for public use, that it involved small areas not contemplated by the Constitution, and that the complaint was defective. The trial court dismissed the motions and declared the plaintiff entitled to take the property upon payment of just compensation. The defendants appealed directly to the Supreme Court.

ISSUE

Whether the expropriation of the subject lots, which are relatively small in area and already subdivided and sold to various individuals, is authorized under Section 4, Article XIII of the Constitution and Commonwealth Act No. 539 for the purpose of resale to tenants and occupants.

RULING

The Supreme Court reversed the order of the trial court and dismissed the expropriation proceedings. The Court held that the expropriation was not authorized. The constitutional provision (Section 4, Article XIII) refers to the expropriation of large landed estates for subdivision and resale at cost. The lots in question, totaling between 67 and 77 hectares and already owned by several individuals in small parcels, do not constitute a “large landed estate” as contemplated by the Constitution. Commonwealth Act No. 539 , which implements this constitutional provision, must be construed as applying only to large estates. The Court further ruled that the expropriation was not for “public use” as it would merely transfer property from one private individual to another, and the beneficiaries (the tenants) do not constitute the general public. The fact that the tenants and their ancestors had occupied the land for years did not justify expropriation, as this would sanction confiscation. The Court distinguished this case from prior rulings involving the same Hacienda Lian, noting that here the estate had already been broken up and sold to small owners before the expropriation suit was filed.