Topic: Flexibility and dynamism

Case: J.M. Tuason & Co., Inc. v. LTA, G.R. No. L-21064, February 18, 1970

Facts:

 August 3, 1959 – RA 2616 (as rightfully amended under RA 3453) took effect without
executive approval, the expropriation of Tatalon Estate in Quezon City by the Petitioners JM
Tuason & Co. was authorized by the Congress in view of social and economic problems.

 November 17, 1960 - the Petitioners JM Tuason & Co. filed special action to nullify RA
2616 directing the expropriation of Tatalon Estate.

 January 10, 1963 - the lower court decided that RA 2616 was unconstitutional, granting the
writ of prohibition.

 The Supreme Court reversed the Lower Court’s decision and the dismissed succeeding
motion for reconsideration.

Issues:

Is RA 2616 (as rightfully amended under RA 3453) is unconstitutional because it violates the
petitioner’s rights to due process and equal protection of the law?

Ruling:

No, RA 2616 (as rightfully amended under RA 3453) is constitutional and does not violate the
petitioner’s rights to due process and equal protection of the law.

The Constitution (1935 as amended, Article XIII Section 3) provides that the Congress may
authorize, upon payment of just compensation, the expropriation of lands to be subdivided into
small lots and conveyed at cost to individuals.

Notwithstanding of the procedural mistakes made, RA 2616 (as rightfully amended under RA
3453) gives protection and opportunity to bona fide land owners in recognizing their right to
expropriation proceedings and just compensation – a barrier to arbitrariness.

The Statue jives with the vision of Dynamism and Public Welfare, as intended by the framers of
the Constitution.

There is nothing to prevent Congress to follow a system of priorities. It could determine which l
and would be first subject of expropriation for valid reasons.

Therefore, RA 2616 (as rightfully amended under RA 3453) is constitutional and does not violate
the petitioner’s rights to due process and equal protection of the law.