CONSTITUTIONAL LAW II REVIEWER

FUNDAMENTAL POWERS OF THE STATE BILL OF RIGHTS

 People vs. Pagal
POLICE POWER
 Venus Commercial vs. DOH Due Process/Equal Protection Clause
 Reyes vs. Rural Bank
EMINENT DOMAIN  Republic vs. Ongpin Page | 1
Necessity of Exercise
 DPWH vs. Manalo Administrative Due Process
 Purisima vs. Ricafranca
Taking Procedural Due Process in Labor Clause
 Municipality of La Carlota vs. NAWASA  Systems & Plan Integrator vs.
 Republic vs. Castelvi Ballesteros

Public Use Due Process in Judicial Proceedings

 Manosca vs. Court of Appeals  Mejia vs. Pamaran

Just Compensation Equal Protection

 Republic vs. Spouses Nocom  DTI vs. Steelasia
 Spouses Buot vs. NTC

SEARCHES/SEIZURES
TAXATION  Calleja vs. Exe. Secretary
Beneficial Use Principle  People vs. Esperidion
 Unimasters vs. Tacloban City  Mendoza vs. People
Government

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Part I. FUNDAMENTAL POWERS OF THE STATE

POLICE POWER: Venus Commercial vs. DOH

Facts:
 The Present case to be when FDA received a letter from Eco-waste Coalition regarding
the alleged high lead content of Artex Fine Water Colors manufactured by petitioner Page | 2
Venus Commercial Co., Inc. sans (without) FDA approval. Acting thereon, FDA purchased
samples of Artex Fine Water Colors and subjected them to laboratory analysis. The
result showed that the amount of lead in each sample exceeded the maximum tolerable
limits prescribed by FDA. Verification with the records of this office also shows that
the aforesaid establishment has no valid license to operate as
manufacturer/distributor of the questioned product.

FDA agents went to implement FDA Personnel Order No. 2014-220 but the security guards
did not allow them. They were consequently restrained to leave, but not without first
serving Venus a Notice of Violation Report.
Issue:
 Do Sections 12(a) and 30 (4) of RA 3720, as amended and Section 2(b) paragraph (5),
Article 3 of Dept. Circular No. 2011-0101 violate the Constitutional proscription
against unreasonable searches and seizures?
Ruling:
 No, it does not violate the Constitutional proscription against unreasonable searches
and seizures.
Police Power is the power of the state to promote public welfare by restraining and
regulating the use of liberty and property. It is the most pervasive, the least limitable,
and the most demanding of the three fundamental powers of the state. The justification is
found in the latin maxim salus populi est suprema lex (the welfare of the people is the
supreme law) and the sic utere tuo ot alienum non laedas (so use your property as not to
injure the property of others). As inherent attribute of sovereignty which virtually extends
to all public needs, police power grants a wide panoply of instruments through which the
State gives effect to a host of its regulatory powers. Also, the proper exercise of police
power requires compliance with the following requisites; (a) the interest of the public
generally, as distinguished from those of a particular class, require the interference of the
State; and (b) the means employed are reasonably necessary to the attainment of the objective
sought to be accomplished and not unduly oppressive upon individuals. In fine, there must be
a concurrence of a lawful subject and lawful method.
Here, FDA Personnel Order No. 2014-220 was issued after the FDA Director-General
confirmed reports about the hazardous lead content of Artex Fine Water Colors and following
the confirmatory results of chemical analysis of product samples. Since the subject water
colors are intended for the use of young students and children in general, the FDA Director-
General found it necessary to immediately order the seizure of the water colors and to order
the temporary closure of the establishments to prevent further harm to this vulnerable sector
of the public.
Therefore, the assailed provisions are deemed Constitutional, and the petition is
hereby dismissed.

Similarities of the Inherent Powers (INIMEL)

1. They are INHERENT and maybe exercised w/o need of express constitutional grant

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2. They are not only NECESSARY but INDESPINSIBLE, they cannot continue or be effective unless it
is able to exercise them
3. They are METHODS by w/c the state interferes with private rights
4. They are pre-suppose an EQUIVALENT compensation for the private rights interfered with them
5. They are generally exercised by LEGISLATURE.
Page | 3

I. POLICE POWER
 State’s authority to enact legislation that may interfere with personal liberty or
property in order to promote general welfare

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 Power of promoting the public welfare by restraining and regulating the use of
liberty or property

Ex. making laws, compelling obedience to those laws through physical means with the
aim of removing liberty, legal sanctions, or other forms of coercion and inducements.

Basis: Page | 4

 Salus Populi Suprema Est Lex (The welfare of the people is the Supreme Law)
 Sic Utere Tuo Ut Alienum Non Laedeas (So use your own property as not to injure another's
property)

Limitations:
A. General: The legislative determination of what is a proper exercise of its police power is not final or
conclusive but is subject to the supervision of the courts.
Balancing is the essence or the indispensable means for the attainment of legitimate
aspirations of any democratic society
B. No conflict with DUE PROCESS and EQUAL PROTECTION of the laws.

TEST OF VALIDITY OF EXERCISE OF POLICE POWER

a. Lawful Object- interest of the public generally as distinguished from particular class required exercise
a. Lawful Method- means employed are reasonably necessary for the accomplishment purpose, and not
unduly oppressive.

WHO MAY EXERCISE?

a. Legislature- Police power is lodged primarily in the national legislature
a. Executive- May be exercised by the president, administrative bodies, and lawmaking bodies of LGU by
virtue of a VALID DELEGATION OF LEGISLATIVE POWER

DUE PROCESS AND POLICE POWER

* a reasonable relation between purposes of the measure and the means employed for its
accomplished must exist so as not to arbitrarily invade such private constitutionally protected rights.
Individual rights may be adversely affected only to the extent that may fairly be required by the legitimate
demands of the public interest or public welfare.

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*THE POWER TO REGULATE DOES NOT INCLUDE THE POWER TO PROHIBIT*

 It does not involve the taking and confiscation of the private property for protecting peace and
order and of promoting general welfare.

Page | 5

II. POWER OF EMINENT DOMAIN

 Inherent power of the State to take private property for public use.

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- Private property shall not be taken without due process of law and payment of
just compensation

Page | 6

*Eminent domain is the power to take, while expropriation is the procedure of taking.

Two situations where the government forced to exercise:

1. When the property owner does not want to sell, then the government has to exercise the power.
2. When the owner wants to sell but does not agree to the price thus the government exercises such power.

Requisites of Exercise of Eminent Domain

1. Necessity – must be of public character
2. Private Property – capable of ownership
3. Taking
4. Public Use – for the benefit of the public
5. Just Compensation
0

EMINENT DOMAIN
Necessity of Exercise
 DPWH vs. Manalo

Facts:
 On November 15, 2010, the Quezon City Task Force Control and Prevention of Illegal
Structures and Squatting issued a Notice of Demolition, asking Manalo et. al to vacate
the land and remove the structures within seven days of receiving the notice. This
came with financial assistance worth P21,000.00 per family. Despite notice, Manalo et.
al refused to vacate the property and accept the financial aid.
DPWH filed an answer praying that the Complaint be dismissed alleging that Manalo et.
al were admittedly squatting on a government-owned property without the owner's
express consent. They also noted that it had already offered Manalo cash compensation
to show good faith and honest intention to help them. Likewise, they refuted their
claim of entitlement to replacement costs, noting that they were only entitled to
financial assistance.
On the other hand, respondents claim that their cause of action remains undeniable, as
they owned the structures that petitioner demolished for the C-5 extension project.
They also argue that the issue they raised was whether they were entitled to just
compensation, over which the trial court has jurisdiction. They also insist that they
are entitled either to the payment of just compensation or to a suitable relocation.
Issue:

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 Are the respondents entitled to just compensation for their structures?

Ruling:
 Yes, they are entitled to just compensation for their structures.

Sec. 10, Article 8 of the 1987 Constitution provides " urban or rural poor dwellers
shall not be evicted, nor their dwellings demolished, except in accordance with law and in
just humane manner." Page | 7

 Here, there is no allegation that a writ of demolition was procured from the
court, or that the procedures provided were observed. Instead, petitioner
admits having offered financial assistance to respondents. By doing this,
petitioner acknowledges that respondents are underprivileged and homeless
citizens, entitled to due process of law, prior to the demolition of their
structures.

Thus, in view of the foregoing, it was determined that respondents had been prejudiced
by the eviction and demolition of their structures and are entitled to damages.

Taking

 A physical dispossession of the owner of his actual property, or its use

 May include trespass without actual eviction of owner, such as the material impairment of value
of property, or preventions of ordinary uses for which the property was intended.
What may be taken?
 All private property capable of ownership including services

Requisites: (PP, MP, CLA, PU, OO)

 The expropriator must enter a private property
 Entry must be for more than a monetary period
 Entry must be under warrant or color of legal authority
 Property must be devoted to public use or otherwise informally appropriated or injuriously
affected
 Utilization of the property must be in such a way as to oust the owner and deprive him of
beneficial enjoyment of the property.

 Municipality of La Carlota vs. NAWASA

Facts:
 The municipality of La Carlota was the owner of the waterworks system serving its
inhabitants until the enactment of RA No. 1383 on June 28, 1955 when, by virtue of its
provisions, the National Waterworks and Sewerage Authority assumed ownership and took
over the supervision, administration and control of the said system, including the
collection of water rentals from the consumers. On April 5, 1960, the municipality
commenced this action in the Court of First Instance of Negros Occidental against the
NAWASA for recovery and accounting.

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Issue:
 Was the transfer of ownership considered taking?
Ruling:
 Yes, the transfer of ownership is considered taking

As stated in Tañada & Fernando, Constitution of the Philippines, 4th ed. Col. 1. Pp
225-216, "ownership is nothing without the inherent rights of possession, control and Page | 8
enjoyment. Where the owner is deprived of the ordinary and beneficial use of his
property or of its being diverted to public use, there is taking within the
constitutional sense.

Here, such deprivation would be the certain consequence if, as prayed for by the
appellant, it should be allowed to assume jurisdiction, supervision and control over
the waterworks system of the appellee. That would be little less than an assumption of
ownership itself and not of mere administration.

 Republic vs. Castellvi

Facts:
 The AFP occupied the land of Carmen M. vda de Castellvi from July 1, 1947, by virtue
of a contract of lease, on a year basis, from July 1 to June 30 of the succeeding
year. The Republic sought to renew the same but Castellvi refused. The AFP refused to
vacate the leased premises after the termination of the contract because it would be
difficult for the army to vacate the premises in view of the permanent installations
and other facilities worth almost P500,000.00 that were erected and already
established on the property. Castellvi then brought a suit to eject APF from the land.
While the ejectment case was pending, the Republic filed on June 26, 1959 complaints
for eminent domain against the respondents over the three parcels of land. In its
complaint, the Republic alleged, among other things, that the fair market value of the
above-mentioned lands, according to the Committee of Appraisal for the Province of
Pampanga, was not more than P2, 000 per hectare. The court authorized the Republic to
take immediate possession of the lands upon deposit of that amount with the Provincial
Treasurer of Pampanga. Furthermore, the lands in the complaint are declared
expropriated for public use, and that the fair market value of the lands is fixed at
P5.00 per square meter.

Issue:
 Was there "taking" when the condemner has entered and occupied the property as lessee.
Ruling:
 Yes, there was taking in this case

Under the power of eminent domain, taking requires two essential elements, to wit: (1)
entrance and occupation by condemn or upon the private property for more than a momentary or
limited period, and (2) devoting it to a public use in such a way as to oust the owner and
deprive him of all the beneficial enjoyment of the property.

In the instant case, by virtue of contract of lease agreement the Republic, through
the AFP, took possession of the property of Castellvi. Also, the aforecited contact of lease
was for a period of one year, renewable from year to year. The entry on the property, under
the lease, is temporary, and considered transitory. The fact that Republic, through AFP,

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constructed some installations of a permanent nature does not alter the fact that the entry
into the land was transitory, or intended to last a year, although renewable from year to
year by consent of 'the owner of the land.'

Thus, the "taking" of the Catellvi's property should not be reckoned as of the year
1947 when the Republic first occupied the same pursuant to the contract of lease, and that
the just compensation to be paid for the Castellvi property should not be determined on the Page | 9
basis of the value of the property as of that year. The lower court did not err when it held
that the "taking" of the property under the expropriation commenced with the filing of the
complaint.

Public Use

*Generally, like roads and schools, property taken must be for public use. And even if the expropriated
property does not directly benefit and be made available to the public, as long as it results to indirect
advantage or benefit of the public welfare.

*It is enough that it serves a public purpose, even if it benefits a large group of people short of the
public in general. The idea of "public use" means "use by the public" has been discarded. At present,
whatever may be beneficially employed for the general welfare satisfies the requirement of public use.

 Manosca vs. Court of Appeals

Facts:
 The petitioners inherited a piece of land located at P. Burgos Street, Calzada,
Taguig, Metro Manila. When the parcel was ascertained by the NHI to have been the
birth site of Felix Manalo, the founder of Iglesia ni Cristo, it passed Resolution No.
1, Series of 1986, pursuant to Section 4 of Presidential Decree No. 260, declaring the
land to be a national historical landmark. Republic filed an urgent motion for the
issuance of an order to permit it to take immediate possession of the property.
Petitioners moved to dismiss the complaint on the main thesis that the intended
expropriation was not for a public purpose and, incidentally, that the act would
constitute an application for public funds, directly or indirectly, for the use,
benefit, or support of Iglesia ni Cristo, a religious entity, contrary to the
provision of Section 29 (2), Article VI of the 1987 Constitution.
Issue:
 Was the expropriation of the land for public use constitutional?
Ruling:
 Yes, the expropriation of the land for public use constitutional.

Public use as one of the fundamental powers of the state in constitutional provisions
restricting the exercise of the right to take private property in virtue of eminent
domain, means a use concerning the whole community as distinguished from particular
individuals. But each and every member of society need not be equally interested in
such use or be personally and directly affected by it; if the object is to satisfy a
great public want or exigency, that is sufficient.

Here, the purpose of setting up the marker is essentially to recognize the distinctive
contribution of the late Felix Manalo to the culture of the Philippines, rather than

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to commemorate his founding and leadership of the Iglesia ni Cristo. The practical
reality that greater benefit may be derived by members of INC than by most others
could well be true, but such a peculiar advantage still remains to be merely
incidental and secondary in nature. Indeed, that only few would actually benefit from
the expropriation of property does not necessarily diminish the essence and character
of public use.
Page | 10
Thus, all considered the court finds the assailed decision to be on accord with law
and jurisprudence.

Just Compensation
 Republic vs. Spouses Nocom
Facts:
 On January 25, 1982, the Manila International Airport Authority instituted
expropriation proceedings for the acquisition of lands originally owned by Emilio Cruz
for the Ninoy Aquino International Airport (NAIA) expansion program. The subject lots,
among others, were included in the Complaint for Expropriation and were to be used as
additional maintenance and parking space for aircrafts in NAIA Terminal 1 Taxiway
06/24.
On June 21, 1991, the RTC of Makati confirmed expropriation of the lots including the
Subject Lots, with an order for MIAA to pay just compensation equivalent to
P552.00/sq.m., plus 6% interest from 1983 until full payment but MIAA assailed the
amount of just compensation. While the appeal was pending, it subdivided each Subject
Lot into two and among the six lots, only Lot 2817-B was found to be within the 150-
meter clearance from the middle of proposed extension of Taxiways 06/24.
Original Certificate Title (OCT) was issued under the names of the heirs of Cruz but
was cancelled and Transfer Certificate Title (TCT) was issued in favor of the Spouses
Nocom, and Spouses Kieng and Chan after the Subject Lots were sold to them by the
heirs of Cruz.
Souses Nocom filed a Petition for Recovery of Possession and Accounting against the
Manila International Airport Authority claiming that MIAA never paid just compensation
and remained in possession of the lots despite the exclusion of the two lots from the
expropriation proceedings. Thus, they prayed that MIAA be ordered to pay rentals for
their use of the lots but MIAA refused to do so asserting that the spouses were not
entitled to rentals as the Motion for Exclusion was void due to the non-fulfillment of
a condition found therein.
Issue:
 Are the Spouses Nocom entitled for just compensation for the rental payments and
interest?

Ruling:
 Yes, Spouses Nocom are entitled for just compensation for the rental payments and
interest of their lands.
As ruled in the case of Republic vs. Hon. Tagle, "The expropriation of real property
does not include mere physical entry or occupation of land. Although eminent domain usually
involves a taking of title, there may also be compensable taking of only some, not all, of
the property interests in the bundle of rights that constitute ownership."

In the instant case, petitioner merely took possession of the lots without initiating
a second expropriation proceeding so it may properly exercise its power of eminent domain.
Contrary to its claim, the previous expropriation judgement did not involve the Subject Lots,
and its continued use of certain portions of the lots in no way transformed its occupation to

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ownership. Accordingly, respondents had no other remedy but to file a suit against petitioner
for the recovery of possession of the property and for payment of reasonable compensation.

Thus, when there is actual taking by the government without expropriation proceedings,
the owner of the property is entitled to just compensation which is pegged at the value of
the property at the time of taking.
Page | 11
 Spouses Buot vs. NTC

Facts:
 Spouses Buot are registered owners of a parcel of land located in Abugon, Sibonga,
Cebu classified as "Agri" in its tax declaration. It was originally registered
pursuant to a grant by free patent carrying a general reservation for all conditions,
public assessments and servitudes as recognized and prescribed by law.

The present case arose when NTC filed a complaint for expropriation with the RTC
against Spouses Buot for the acquisition of a 196-square meter portion of the subject
property and the enforcement of right-of-way for its upgrading project.

Spouses Buot opposed the complaint and countered that the danger, hazard, and adverse
effects on the safety and health of persons posed by the tower would consequently
render the subject property useless. Thus, they sought just compensation for their
entire lot because the already existing transmission lines traversing and occupying
portion of their lad, plus the present proposed area Upgrading Project would affect a
bigger area.
Issue:
 Whether the CA gravely erred in remanding the case to RTC for determination of just
compensation among others?

Ruling:
 No, CA's remanding of the case to RTC was meritorious.

The Court reiterated the Andaya Doctrine in the case of Bartolata v. Rep of the
Phils., where it listed the two elements that must concur before a property owner can become
entitled to just compensation for the remaining property under Section 112 of the Public Land
Act; "(1) that the remainder is not subject to the statutory lien of right-of-way; and (2)
that the enforcement of the right-of-way results in the practical destruction or material
impairment of the value of the remaining property, or in the property owner being disposed or
otherwise deprived of the normal use of the said remainder.

The Court is mindful of the fact that the construction of power or transmission lines
would inevitably impose limitations on the land, which would, in turn, indefinitely deprive
the property owners of its normal use. The presence of the transmission lines, too, would
undoubtedly restrict the property owner's use of the property, and it may even endanger the
lives and limbs because of the high-tension electric current conveyed through the lines.

Thus, taking these factors into serious consideration, there is no question that
Spouses Buot are entitled to consequential damages for the areas before and in between the
transmission lines that lie outside the 60-meter wide easement, if any, which would be
rendered unusable or uninhabitable because of the traversing transmission lines.

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Page | 12

III. POWER OF TAXATION

 The power by w/c the sovereign, through its law-making body, raises revenue to
defray the necessary expenses of the government.

Taxation- merely a way of proportioning the costs of government among those who in some measures
are privileged to enjoy its benefits and must bear its burdens.

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 CONSTITUTIONAL LAW II REVIEWER

Page | 13

What are the inherent limitations on

taxation? Explain. (2009 Bar) (PINGS)
The inherent limitations on taxation are:

1. Taxes must be exacted for a Public

purpose. This does not only pertain to
those purposes which are
traditionally viewed as essentially
government functions, such as building
roads and delivery of basic
services, but also include those purposes
designed to promote social justice
(Planters Products, Inc. v.
Fertiphil Corp., G.R. No. 166006, March 14,
2. International comity. Under this
principle, a state must recognize the
generally accepted tenets of
international law, among which are the
principles of sovereign equality among
states and of their freedom
Sec. 28, Art. 6. from suit without their consent, that limit
LBI (Lands, Buildings, the authority of a government to
Improvements
effectively impose taxes on a
sovereign state and its instrumentalities, as
ADE (Actually, Directly, well as on its property held, and activities
Exclusively) undertaken, in that
capacity (VITUG & ACOSTA, Tax Law, supra
RCE (Religious, Charitable, at 11);
Educational)
3. Non-delegability of the taxing power. As
a general rule, the power to tax is
exclusively vested in the

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legislative body (DIMAAMPAO, Tax Principles and Remedies, supra at 52). This is embodied in the
Latin maxim “Potestas Delegata Non Delegari Potest” which means, what has been delegated may not
be delegated. This is based on the ethical principle that a delegated power is not only a right but a duty
that the delegate must perform through the instrumentality of his own judgment and not through the
intervening mind of another (Quezon City PTCA Federation, Inc. v. Department of Education, G.R. No.
188720, February 23, 2016);
Page | 14
4. Government entities, agencies and instrumentalities are generally exempt from taxation.
Otherwise, it will result in the absurd situation of the government taking money from one pocket and
putting it in another (Board of Assessment Appeals of Laguna v. Court of Tax Appeals, G.R. No. L-18125,
May 31, 1963);

5. Territoriality or Situs. The situs of taxation is the place or authority that has the right to impose and
collect taxes. Taxation may be exercised only within the territorial jurisdiction of the taxing authority
(Commissioner of Internal Revenue v. Marubeni Corp., G.R. No. 137377, December 18, 2001).

Beneficial Use Principle

 Unimasters vs. Tacloban City Government

Facts:
 Leyte Park Hotel Inc. (LPH)) is co-owned by Assets Privatization Trust (APT),now
Privatization Management Office (PMO), the Province of Leyte,etc. On Sept. 15, 1994,
then APT, representing the owners of LPHI, and UCI through its president entered into
a contract of lease over LPHI with a duration of 12 years.

Initially, UCI was faithfully paying its monthly rentals and real property taxes, the
latter payments were subsequently credited to its rental payment. However, starting
December 16, 2000, UCI stopped paying its obligations, prompting PMO to send several
letters demanding compliance with the provisions of the contract. Even so, the
agreement expired without UCI settling its obligations. Since then, UCI has retained
possession and enjoyment of the premises without paying any rentals and taxes due.

Meanwhile, the City Treasurer of Tacloban sent several demand letters to Chan to
collect unpaid real property taxes of LPHI but the same remained unpaid despite
notice. Hence, the City Treasurer of Tacloban instituted a collection case against
LPHI, UCI, APT, PTA, and the Province of Leyte before the CTA.
Issue:
 Is UCI liable to pay real property taxes?
Ruling:
 Yes, UCI is liable to pay real property taxes

Section 234 (a) of the Local Government Code provides "Real property owned by the
Republic of the Philippines or any of its political subdivisions except when the beneficial
use thereof has been granted, for consideration or otherwise to a taxable person" It is
noticeable that the above-mentioned provision also contains limitation to the exemption
granted to the Republic or any of its political subdivisions when the beneficial use of the
real property it owns is granted to a taxable person.

Here, the hotel, which is the subject matter of this case, is owned in common by the
Province of Leyte, which is a political subdivision, and by PMO and PTA, both government

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instrumentalities that are exempt from payment of real property taxes. The subsequent
execution of a Contract of Lease between the co-owners of LPHI and UCI, a private entity, did
not divest the former of their exemption from real property taxes, only that the hotel lost
the exemption from being taxed and the burden to pay the taxes due thereon, passed on to UCI
as beneficial user thereof.

Page | 15
Thus, UCI is liable to pay said real property taxes.

Student: JACKELYN AMANTE GREMIO