Title: Mactan-Cebu International Airport Authority and Air Transportation Office v.

Bernardo L. Lozada, Sr., and the Heirs of Rosario Mercado

G.R. No.: 176625

Date: February 28, 2006

Facts: The case involved the expropriation of a property for the expansion and
improvement of an airport. The property owner, respondent Bernardo L. Lozada, Sr.,
acquired the property and later entered into a compromise settlement with the
government that the property would be resold to him if the intended expansion and
improvement of the airport did not materialize. The airport's expansion did not take
place, and the property was converted into a commercial complex. Respondents filed a
case for recovery of possession and ownership of the property based on the alleged
compromise settlement.

Issue: Whether respondents have the right to repurchase the property due to the
abandonment of the airport's expansion and improvement, as per the alleged
compromise settlement.

Ruling: Yes, respondents have the right to repurchase the property. The Court held that
the expropriation of private property by the government's power of eminent domain is
subject to the condition that the property be devoted to the specific public purpose for
which it was taken. If this purpose is not initiated or not pursued, the former owners
have the right to seek reacquisition of the property. The Court also ruled that the Statute
of Frauds does not apply to executed or partially performed contracts. Respondents'
oral compromise agreement was considered partially performed, and their right to
repurchase the property was upheld.

Legal Principle: The taking of private property by the government's power of eminent
domain is subject to the condition that the property be devoted to the specific public
purpose for which it was taken. If this purpose is not initiated or pursued, the former
owners have the right to seek reacquisition of the property, subject to returning the
compensation received.

Significance: This case illustrates the fundamental principle that the government's
power of eminent domain is not absolute and is subject to certain conditions, including
the specific public purpose for which the property is taken. If the government fails to
fulfill this purpose, the former property owners have the right to seek the return of their
property. It also clarifies that the Statute of Frauds does not apply to executed or
partially performed contracts, allowing parties to enforce oral agreements when they
have been partially acted upon.

Case Title: Republic of the Philippines, represented by the General Manager of the
Philippine Information Agency (PIA) v. THE HONORABLE COURT OF APPEALS Heirs of
Luis Santos

G.R. No. 146587

Date: July 2, 2002

Court: Supreme Court of the Philippines, First Division

Background: The case involves an expropriation proceeding initiated by the Republic of

the Philippines to acquire certain properties for the continued broadcast operation of a
radio transmitter project. The government took possession of the property in 1969 but
failed to pay just compensation to the heirs of Luis Santos, who owned a portion of the
expropriated land. The trial court issued a decision in 1979 ordering the government to
pay compensation. However, the government did not pay, and the heirs filed a motion
for payment in 1984. The trial court granted the motion and ordered partial payment.
Subsequently, the property was partly transferred to a university. The government
sought to deposit compensation in 1999, but the heirs demanded an adjustment in
compensation.

Issues:

1. Whether the government's failure to pay compensation within five years

rendered the judgment unenforceable.
2. Whether the heirs were entitled to the return of the expropriated property.
3. Whether the government's delay in payment constituted laches.

Ruling: The Supreme Court held that the government's power of eminent domain is a
fundamental power of the state that allows the acquisition of property for public use.
The court noted that the expropriation proceedings had conferred ownership of the
property upon the government. The court rejected the heirs' argument that the change
in the property's use over time affected its public nature. The court emphasized that the
government has the right to determine the use of the expropriated property as long as
it is for public use. The court also clarified that the government's delay in payment did
not render the judgment unenforceable and that the heirs were entitled to
compensation for the property's value at the time of taking, with interest.

The court ruled that the heirs were not entitled to the return of the expropriated
property but should be promptly paid the compensation awarded in the 1979 decision.
The court held that the trial court acted beyond its authority in vacating its 1979
decision and ordered the reinstatement of that decision.

Significance: This case emphasizes the government's fundamental power of eminent

domain and its authority to determine the use of expropriated property for public
purposes. The case also clarifies that a delay in paying compensation does not render
the judgment unenforceable, and the owners are entitled to compensation with interest.
The case underscores the importance of prompt and fair compensation in eminent
domain cases while ensuring that public use objectives are met.

Case: Estate of Heirs of the Late Ex-Justice Jose B.L. Reyes and Estate or Heirs of
the Late Dr. Edmundo Reyes vs. City of Manila

G.R. No. 132431 and G.R. No. 137146, February 13, 2004

Facts:

This case involves a petition for review and certiorari filed by the heirs of Jose B.L. Reyes
and Edmundo Reyes against the City of Manila and other parties. The City of Manila
filed an expropriation case over parcels of land owned by the petitioners, citing its
power of eminent domain granted by the Local Government Code and an enabling
ordinance. The petitioners challenged the legality of the expropriation and the
subsequent protective orders issued by the Court of Appeals, which prohibited the
execution of final judgments in ejectment cases related to the same properties.

Issues:

1. Whether the City of Manila can legally exercise its power of eminent domain in
the expropriation of the subject properties.
2. Whether the protective orders issued by the Court of Appeals are valid and
justified.

Ruling:
 1. No. The Court ruled that the City of Manila failed to comply with the conditions
and standards prescribed by RA 7279 (The Urban Development and Housing Act
of 1992) in its expropriation proceedings. The law provides a specific order of
priority for acquiring lands for socialized housing, with private lands ranking last.
Expropriation can only be resorted to after exhausting other modes of
acquisition. Since the City did not prove compliance with these requirements, the
expropriation of the subject properties was deemed illegal and a violation of due
process.
2. The issue of protective orders became moot due to the dismissal of the
expropriation case. The Court did not address the validity of these orders as the
primary issue was the legality of expropriation. However, it highlighted the
importance of vigilance in complying with due process requirements even in
cases involving the power of eminent domain.

Significance:

This case highlights the fundamental power of the State to exercise eminent domain,
which allows the government to take private property for public use. However, this
power is not absolute and is subject to certain conditions and standards, particularly
when it comes to acquiring property for socialized housing. The case emphasizes the
need for the State to adhere to due process and legal requirements in exercising its
powers, and it also underscores the role of the judiciary in safeguarding individual rights
in the face of government actions.

Case: Bataan Shipyard & Engineering Co., Inc. (BASECO) vs. Presidential
Commission on Good Government (PCGG)

G.R. No. 75885, May 27, 1987

Facts:

The petitioner, Bataan Shipyard and Engineering Co., Inc. (BASECO), was alleged to have
been owned or controlled by President Marcos during his administration through
nominees, with undue advantage taken of his public office. After Marcos' flight from the
country, certificates corresponding to more than 95% of BASECO's outstanding shares
of stock were found in Malacañang, endorsed in blank. The PCGG issued sequestration
orders on BASECO based on Executive Orders No. 1 and 2 promulgated by President
Corazon Aquino.

Issues:
 1. Are the provisional remedies involved in this case unconstitutional?
2. Did PCGG and its Commissioners act without or in excess of their powers, or with
grave abuse of discretion?
3. Was there a violation of the right against self-incrimination and unreasonable
searches and seizures?

Ruling:

1. No. The Provisional or "Freedom" Constitution recognizes the power of the

President to enact measures to recover ill-gotten properties and protect the
interest of the people through orders of sequestration or freezing of assets. This
authority is further ratified by the 1987 Constitution. The State's inherent police
power, aimed at promoting public welfare and protecting public interest, justifies
the use of provisional remedies.
2. No. PCGG's role involves conducting investigations, collecting evidence of ill-
gotten wealth, issuing sequestration orders, and taking necessary actions to
preserve assets. PCGG's actions are not final or adjudicative; they are preparatory
and investigative in nature.
3. No. The right against self-incrimination does not apply to juridical persons like
corporations. While individuals can refuse to answer incriminating questions,
corporations do not have the same privilege when charged with abusing their
privileges and franchises.

This case showcases the exercise of fundamental powers of the State, including police
power and the power to investigate and take provisional measures to protect public
interest. It also underscores the distinction between individuals and juridical persons
when it comes to constitutional rights.

G.R. No. 74457 March 20, 1987

RESTITUTO YNOT, petitioner, vs. INTERMEDIATE APPELLATE COURT, THE

STATION COMMANDER, INTEGRATED NATIONAL POLICE, BAROTAC NUEVO,
ILOILO and THE REGIONAL DIRECTOR, BUREAU OF ANIMAL INDUSTRY, REGION
IV, ILOILO CITY, respondents.
Ramon A. Gonzales for petitioner.

CRUZ, J.:

Essence of Due Process - Executive Order No. 626-A

This case revolves around the constitutionality of Executive Order No. 626-A, which bans
the interprovincial transport of carabaos and carabeef and mandates their confiscation
in cases of violation.

Facts:

The petitioner transported six carabaos from Masbate to Iloilo, where they were
confiscated by the police for violating Executive Order No. 626-A. The petitioner
challenged the constitutionality of the order, arguing that it deprived him of his
property without due process. The trial court upheld the confiscation and declined to
rule on the order's constitutionality. The appellate court affirmed the trial court's
decision, leading the petitioner to file a petition for review.

Issue:

Is Executive Order No. 626-A constitutional, considering its prohibition of interprovincial

transport of carabaos and carabeef and the immediate confiscation of the same?

Ruling:

The Supreme Court ruled that Executive Order No. 626-A is unconstitutional due to its
violation of due process and improper exercise of the police power.

Rationale:

1. Due Process and Police Power: The Court emphasized that due process, the
essence of which is "Strike — but hear me first," demands that individuals be
given a chance to be heard and present their case before judgment. The police
power, while powerful, must still respect due process.
2. Validity of Prohibition: The Court acknowledged the importance of protecting
carabaos for agricultural purposes. However, it found that banning interprovincial
transport was not reasonably necessary to achieve this purpose. The connection
between the prohibition and preventing indiscriminate slaughter was not evident.
 3. Penalty and Due Process: The Court noted that the penalty under the order was
confiscation, which was carried out immediately by the police. This denied the
owner the right to be heard and violated due process. Only a court should have
the authority to impose penalties after trial and conviction.
4. Delegation of Legislative Power: The Court found that the order improperly
delegated legislative powers by granting the authorities discretion in distributing
the confiscated property. The phrase "may see fit" was too broad and lacked
reasonable guidelines.

Conclusion:

The Court declared Executive Order No. 626-A unconstitutional due to its violation of
due process, improper exercise of police power, and improper delegation of legislative
powers. The Court emphasized that due process requires fairness, respect for individual
rights, and adherence to the rule of law.

Significance:

This case highlights the importance of due process in exercising government power and
the need for a reasonable nexus between a measure and its intended purpose. It also
underscores the dangers of vague delegation of powers, which can lead to abuse and
arbitrariness.

Case Digest: Bai Sandra Sema v. Commission on Elections (G.R. No. 177597, 558
SCRA 700)

Facts: The Province of Maguindanao is part of the Autonomous Region in Muslim

Mindanao (ARMM). Cotabato City is within Maguindanao but is not part of ARMM due
to a plebiscite in 1989. Maguindanao has two legislative districts, and the 1st district
includes Cotabato City and eight other municipalities. Republic Act (RA) 9054 amended
ARMM's Organic Act, granting ARMM the power to create provinces, municipalities,
cities, and barangays. Pursuant to this law, the ARMM Regional Assembly created Shariff
Kabunsuan under Muslim Mindanao Autonomy Act 201, comprising the municipalities
of the 1st district of Maguindanao except Cotabato City.

For the 2007 elections, the Commission on Elections (COMELEC) initially considered the
1st district to consist only of Cotabato City due to MMA 201. However, COMELEC later
modified this stance, maintaining the status quo and designating the district as Shariff
Kabunsuan with Cotabato City, pending a decisive declaration from Congress regarding
Cotabato's legislative district status. Bai Sandra Sema, a congressional candidate for the
legislative district of Shariff Kabunsuan with Cotabato, argued that Cotabato City should
have its separate legislative district, asserting that the creation of Shariff Kabunsuan
under RA 9054 was unconstitutional.

Issues:

1. Whether RA 9054 is unconstitutional.

2. Whether ARMM can validly create LGUs.

Held: RA 9054 is unconstitutional, and ARMM cannot validly create LGUs.

1. The creation of local government units is governed by Section 10, Article X of the
Constitution, which requires compliance with criteria established in the Local
Government Code, no conflict with the Constitution, and a plebiscite in the
affected political units. While Congress can delegate power to create LGUs to
local legislative bodies, this delegation must adhere to reasonable standards and
not contradict the Constitution. ARMM lacks authority to create provinces since it
cannot create legislative districts, which is solely Congress's power. Creation of a
city necessitates a population of at least 250,000.
2. ARMM cannot create Shariff Kabunsuan province as it lacks the authority to
create legislative districts. ARMM's jurisdiction extends only to creating
barangays, not cities or provinces.

In conclusion, RA 9054 is unconstitutional regarding ARMM's power to create LGUs, and

ARMM's authority is limited to creating barangays. Cotabato City's population did not
meet the requirement for a separate legislative district. Additionally, ARMM's creation of
Shariff Kabunsuan province is legally untenable without a legislative district, a power
vested solely in Congress.

Significance: This case underscores the principles of delegation of powers in

constitutional law. It emphasizes that delegation of power to create LGUs should adhere
to reasonable standards and constitutional compliance. The case also clarifies the extent
of ARMM's authority in creating LGUs and highlights the importance of complying with
constitutional requirements when establishing new political units.

Case Digest: Datu Zaldy Uy Ampatuan v. Hon. Ronaldo Puno (G.R. No. 190259,
June 7, 2011)

Facts: On November 24, 2009, following a gruesome massacre of 57 individuals,

including journalists, then President Gloria Macapagal-Arroyo issued Proclamation 1946,
placing Maguindanao, Sultan Kudarat, and Cotabato City under a state of emergency.
She directed the Armed Forces of the Philippines (AFP) and the Philippine National
Police (PNP) to take necessary measures to prevent and suppress lawless violence.
Subsequently, Administrative Order 273 (AO 273) was issued, transferring the
supervision of the Autonomous Region in Muslim Mindanao (ARMM) from the Office of
the President to the Department of Interior and Local Government (DILG). This was later
amended by Administrative Order 273-A (AO 273-A), which delegated supervision to
the DILG. ARMM officials, led by Datu Zaldy Uy Ampatuan, Ansaruddin Adiong, and
Regie Sahali-Generale, filed a petition for prohibition, arguing that these actions violated
the principle of local autonomy and the Constitution. They also challenged the factual
basis for these actions.

Issues:

1. Whether Proclamation 1946 and AOs 273 and 273-A violate the principle of local
autonomy.
2. Whether President Arroyo unlawfully exercised emergency powers.
3. Whether the President had factual bases for her actions.

Ruling: The Supreme Court dismissed the petition.

1. The Court ruled that the DILG Secretary did not take over control of the ARMM's
powers. The succession rule was followed, and the ARMM officials continued to
manage the region.
2. The deployment of AFP and PNP personnel was not an exercise of emergency
powers as defined by the Constitution. The President did not proclaim a national
emergency but rather a state of emergency in specific places. The Constitution
directly vests the power to call out the armed forces in the President, and she did
not need congressional authorization to do so.
3. The President's power to call out the armed forces to prevent or suppress lawless
violence is based on Section 18, Article VII of the Constitution. The Court
acknowledged the President's judgment in determining the need for such action,
unless it's shown that the determination was attended by grave abuse of
discretion. In this case, the President's actions were based on credible intelligence
reports indicating imminent violence and anarchy. The Court respected the
President's actions and upheld the factual bases.

Significance: This case addresses the balance between the President's authority to call
out the armed forces and the autonomy of local government units. It underscores the
deference given to the President's judgment in determining the need for such actions
and the importance of credible intelligence reports as factual bases. The case also
clarifies that the deployment of troops in response to specific incidents does not
necessarily constitute an exercise of emergency powers as defined by the Constitution.

Case Digest: A.M. No. SCC-13-18-J (Baguan M. Mamiscal v. Clerk of Court

Macalinog S. Abdullah, Shari'a Circuit Court)

Facts: The case involves a complaint filed by Baguan M. Mamiscal against Macalinog S.
Abdullah, Clerk of Court of the Shari'a Circuit Court in Marawi City, Philippines. Mamiscal
alleged that Abdullah, in his capacity as Clerk of Court and Circuit Civil Registrar,
registered his divorce with Adelaidah Lomondot without following proper procedures.
Mamiscal claimed that the divorce was invalid and that Abdullah's actions were biased,
violated due process, and constituted misconduct.

Issue: The primary issue in this case is whether the Supreme Court has jurisdiction to
impose administrative sanctions against Abdullah for his actions as Circuit Civil Registrar
in registering the divorce.

Ruling: The Supreme Court ruled that it does not have jurisdiction to impose
administrative sanctions against Abdullah for his actions as Circuit Civil Registrar. It
highlighted that while the Clerk of Court of the Shari'a Circuit Court is a member of the
Judiciary, the registration of civil status falls under the jurisdiction of the National
Government and the local government units. Specifically, the Civil Registrar-General and
the municipal and city mayors have the authority to exercise administrative supervision
over civil registrars, including Circuit Civil Registrars. The Court noted that the Civil
Service Commission (CSC) also holds jurisdiction over administrative cases and can hear
and decide cases involving government officials and employees.

Therefore, the Supreme Court dismissed the administrative matter against Abdullah for
lack of jurisdiction. The complaint was referred to the Office of the Mayor in Marawi City
and the Civil Service Commission for appropriate action.

Significance: This case underscores the delineation of jurisdiction between different

government entities in matters of civil registration and administrative supervision. It
clarifies that the Supreme Court does not have jurisdiction to impose administrative
sanctions on civil registrars, as this authority lies with the Civil Registrar-General, the
municipal and city mayors, and the Civil Service Commission. The ruling emphasizes the
importance of adhering to the appropriate administrative and legal channels in
addressing grievances related to civil registration procedures.