Reyes et al. vs.

NHA
G.R. No. 147511, January 20, 2003

Facts:
National Housing Authority, respondent, expropriated the petitioners’ lot for the
expansion of the Dasmarinas Resettlement Project for the accommodation of the
squatters relocated from Metro Manila. However, the petitioners allege that respondent
did not comply with the decision of the court as the lots were not used for the stated
purpose of the relocation of the squatters from the Metropolitan area and there was no
just compensation that they received from the respondent. They demand that NHA be
forfeited from the rights of those lots and those lots should be returned to the previous
owners. Respondent NHA then answered that it cannot do so since a substantial amount
was already paid to the petitioners and that the expropriation judgement of the court
could not be followed because of several issues stated by the respondents before the
expropriation court. The trial court then conducted an ocular inspection where they found
that the lots already had some relocatees living there. The trial court then dismissed the
complaint and held that: 1) NHA did not abandon the public purpose od expropriating the
land; 2) no condition was imposed that the lots would be returned to the owners if it
would be found that the purpose of expropriation is terminated or abandoned, 3) just
compensation is independent of the obligation of the petitioners to pay the capital gains
tax; and 4) the payment of just compensation should be valued at the time the property
was taken. The Court of Appeals affirmed the Trial Court’s decision.

Issue: Whether or not the NHA deviated from the stated public use of the expropriated
lots

Ruling:
No. The Supreme Court ruled that respondent did not abandon the public use of
the lots. Public use is defined to be synonymous with “public interest”, “public benefit”,
“public welfare”, and “public convenience.” The act of the respondent of contracting with
a private contractor to build low cost houses to be sold to low-income beneficiaries does
not mean the NHA deviated from the intended public use. The court also stated that “the
Constitution itself allows the State to undertake, for the common good and in
cooperation with the private sector, a continuing program of urban land reform and
housing which will make at affordable cost decent housing and basic services to
underprivileged and homeless citizens in urban centers and resettlement areas.” It was
also stated in the decision of the expropriation court that NHA is allowed to develop the
lots for public use or purpose of expanding the Dasmarinas Resettlement Project. This
means that the lots are not strictly used for the resettlement of the squatters. Therefore,
the appealed judgement is modified with requiring the NHA to pay just compensation
with legal interest and the petitioners to pay the capital gains tax and surrender to NHA
any duplicate copies of the certificate of titles of the lots upon full payment of just
compensation.