Manosca v. CA

G.R. No. 106440 (January 29, 1996)

Facts:

The case involves a parcel of land located at P. Burgos Street, Calzada, Taguig, Metro Manila, measuring approximately 492 square meters, which was inherited by the petitioners, Alejandro Manosca, Asuncion Manosca, and Leonica Manosca. This land was declared a national historical landmark by the National Historical Institute (NHI) through Resolution No. 1, Series of 1986, due to its significance as the birthplace of Felix Y. Manalo, the founder of the Iglesia Ni Cristo. The resolution was approved by the Minister of Education, Culture and Sports on January 6, 1986.

Following this declaration, the Secretary of Justice issued Opinion No. 133, Series of 1987, affirming the legality of the NHI's resolution and stating that the expropriation of the land for public use was justified as it was associated with an important event in Philippine history. Consequently, on May 29, 1989, the Republic of the Philippines, represented by the Office of the Solicitor General, filed a complaint for expropriation against the petitioners, asserting that the land was needed for a public purpose as a national historical landmark.

The trial court authorized the Republic to take immediate possession of the property after fixing the provisional market value at P54,120.00 and the assessed value at P16,236.00. The petitioners opposed the expropriation, arguing that it was not for a public purpose and that it would indirectly benefit a religious entity, which they claimed was contrary to Section 29(2), Article VI of the 1987 Constitution. They also sought to dismiss the complaint and suspend the implementation of the trial court's order.

The trial court denied the petitioners' motion to dismiss and their subsequent motions for reconsideration. The petitioners then filed a petition for certiorari and prohibition with the Court of Appeals, which dismissed their petition, stating that the ordinary remedy of appeal was adequate and that there was no grave abuse of discretion by the trial court.

Legal Issues:

1. Whether the expropriation of the land for the purpose of establishing a national historical landmark constitutes a "public use" under the doctrine of eminent domain.
2. Whether the expropriation violates the constitutional prohibition against the appropriation of public funds for the benefit of a religious entity.
3. Whether the petitioners were denied due process in the determination of the provisional value of their property.

Arguments:

• Petitioners' Arguments:

  • The expropriation does not serve a public purpose as defined by existing jurisprudence, which they argue should be limited to traditional public uses such as roads, schools, and parks.
  • The intended use of the property would primarily benefit the Iglesia Ni Cristo, a religious organization, which they claim is contrary to the constitutional prohibition against using public funds for religious purposes.
  • They contend that they were denied due process in the fixing of the provisional value of their property, as they were not given a fair opportunity to contest the valuation.

• Respondents' Arguments:

  • The Republic argues that the expropriation is justified as it serves a public purpose by preserving a site of historical significance, which benefits the community at large.
  • They assert that the incidental benefit to the Iglesia Ni Cristo does not negate the public purpose of the expropriation, as the recognition of historical contributions is a matter of public interest.
  • The respondents maintain that the petitioners had ample opportunity to present their case regarding the valuation of the property and that due process was observed.

Court's Decision and Legal Reasoning:

The Supreme Court upheld the decision of the Court of Appeals, affirming that the expropriation of the land for the purpose of establishing a national historical landmark constitutes a valid exercise of the power of eminent domain. The Court reasoned that the concept of "public use" has evolved and is not strictly limited to traditional uses. It emphasized that public use encompasses any use that meets a public need or exigency, which can include the preservation of sites of historical significance.

The Court rejected the petitioners' argument that the expropriation primarily benefits a religious organization, stating that the primary objective is to recognize Felix Y. Manalo's contributions to Philippine culture and history. The incidental benefits to the Iglesia Ni Cristo were deemed secondary and did not detract from the public purpose of the expropriation.

Regarding the due process claim, the Court found that the petitioners were given sufficient opportunity to contest the valuation of their property and that the trial court's procedures were in accordance with the law.

Significant Legal Principles Established:

1. The definition of "public use" in the context of eminent domain is broad and includes the preservation of historical sites, which serve the public interest.
2. The incidental benefit to a specific group, such as a religious organization, does not invalidate the public purpose of an expropriation.
3. Due process in expropriation proceedings requires that property owners have the opportunity to be heard, which was satisfied in this case.