SALAS v.

JARENCIO

Facts:
Municipal Board of Manila adopted a resolution requiring the Pres. to consider the feasibility of
declaring an area to be a patrimonial property of Manila for the purpose of reselling these lots to the
actual occupants. RA 4118 was passed declaring the area as an alienable/disposable land of the State, to
be placed under the Land Tenure Administration(Land Authority). Gov. Yap of Land Authority wrote
letter to Mayor of Manila for the proposed subdivision plan of w/c Manila accepted.  But due to
unknown reasons, Manila decided to go against their “agreement” and prayed that RA 4118 be not
implemented and that it is unconstitutional.
Respondent Judge Jarencio declared that RA 4118 is unconstitutional and invalid, thus the petition for
review.

 Issue:
Is RA 4118 valid?

Held:
VALID! Manila has not shown any evidence that it acquired said land as private or patrimonial property.
Further, RA 4118 was intended to implement the social justice policy of the Constitution and the “Land
for the Landless” program. The RA was never intended to expropriate the property involved but
confirmed its character as communal land of the State and to make it available for disposition by the
Nat’l Gov’t through the Land Authority.

(STATCON PRINCIPLE: PRESUMPTION OF CONSTITUTIONALITY OF STATUTES)

Presumption is always in favor of the constitutionality of the law. To declare a law as unconstitutional,
the repugnancy must be clear and unequivocal. To strike down a law, there must be a clear showing that
what the fundamental law condemns or prohibits, the statute allows it to be done.