G.R. No.

L-2089, October 31, 1949

JUSTA G. GUIDO, petitioner,

vs.
RURAL PROGRESS ADMINISTRATION, c/o FAUSTINO AGUILAR, Manager, Rural Progress Administration,
respondent.

Guillermo B. Guevara for petitioner.

Luis M. Kasilag and Lorenzo B. Vizconde for respondent.

TUASON, J.:

FACTS:

Justa Guido, the owner of the land expropriated by the Rural Progress Administration (RPA), filed a motion asking
the RPA and Judge Oscar Castelo to enjoin the expropriation process. Mr. Guido argued, that the expropriated land
was commercial land and therefore did not fall within the scope of the provisions of Law No. 539. Commonwealth
Act No. 539 authorized the President of the Philippines to acquire private land or interests therein by buyers or
farms for resale at a reasonable price. The National Assembly approved this Decree based on Article 4

ISSUES:

Whether Guido’s land expropriation is accordant with the principle of social justice or not

HELD:

NO. The Philippines is a democratic country created to ensure the well-being and economic security of the Filipino
people through a regime of justice, liberty, and democracy. The Constitution promotes freedom, economic freedom,
and enterprise within reasonable limits. However, it does not advocate for the destruction of property rights or equal
distribution of wealth.

The promotion of social justice does not guarantee the untrammeled expropriation of private land by government
instrumentalities. Social justice focuses on equality of opportunity, political rights, and equality before the law.

Expropriation of large estates, perpetual trusts, and lands has direct public welfare implications. However, the
condemnation of small properties in the name of individuals and their families does not secure a public interest of a
sufficient degree to make the use public. The present case lacks many elements that contribute to public interest or
use.