City of Manila vs. Alejandro Roces Prieto et al.: A Critique on Compliance with Philippine Eminent Domain Laws
### Facts
On January 19, 2004, the City Council of Manila enacted Ordinance No. 8070, empowering the Mayor to acquire lands from Alejandro Roces Prieto and other respondents for the Land-For-The-Landless Program. The City’s offer of P2,000.00 per square meter was declined by respondents, prompting a complaint for expropriation filed on September 3, 2004, in the Regional Trial Court (RTC) of Manila. The City sought a writ of possession, pledging over 100% of the properties’ assessed value as deposit.
The RTC initially denied the writ for failure to meet the Local Government Code’s 15% of fair market value deposit requirement. Following compliance, a Writ of Possession was issued on October 6, 2006. The RTC later found the City’s expropriation attempt lawful, endorsing it for the public purpose outlined. Respondents’ motions for reconsideration were denied on January 22, 2013.
Appealing to the Court of Appeals (CA), the decision was overturned. The CA criticized the lack of rigorous compliance with rules governing eminent domain, noting failures in demonstrating the necessity and lack of exhaustive efforts to acquire the property through other means, as mandated by the law, notably under the Urban Development Housing Act of 1992.
### Issues
1. Whether the CA erred in ruling that the City failed to prove compliance with the legal requisites for exercising its power of eminent domain.
2. If the requirements under the Local Government Code and the Urban Development Housing Act of 1992 were properly adhered to by the City of Manila in its expropriation efforts.
### Court’s Decision
The Supreme Court affirmed the CA’s decision, holding that the City’s exercise of eminent domain did not rigorously comply with statutory requirements. Specifically, it highlighted:
– The failure to demonstrate the lack of viable alternatives to expropriation.
– Insufficient proof that the property was of the specific category suitable for expropriation under the Urban Development Housing Act.
– Lack of evidence to substantiate the claim that the properties were located in areas necessitating on-site development over other forms of acquisition.
– The City’s failure to renegotiate the purchase price with the property owners before pursuing expropriation.
### Doctrine
1. **Strict compliance with legal requisites in the exercise of eminent domain:** The ruling reinforces the doctrine that delegated power of eminent domain to local government units must strictly adhere to the explicit statutory requirements for its exercise, emphasizing due diligence, fair negotiation, and justification of public use.
2. **Prioritization of negotiated acquisition over expropriation:** Demonstrated by the City’s failure to adequately negotiate property acquisition before resorting to expropriation, as highlighted in the decision.
### Class Notes
– **Eminent Domain:** A government’s right to expropriate private property for public use, with compensation.
– **Legal Framework:** Local Government Code and the Urban Development Housing Act of 1992 define strict protocols and criteria, emphasizing negotiation before expropriation, prioritization of land acquisition modes, and the need for a clear public purpose.
– **Public Use Requirement:** There must be a clear indication that the expropriation of property is intended for a legitimate public purpose.
– **Negotiated Purchase:** Before pursuing expropriation, all reasonable efforts to acquire the property through negotiation must be exhausted.
– **Just Compensation:** Property owners are entitled to fair market value compensation for their expropriated property.
### Historical Background
This case sits against the backdrop of the Philippines’ broader efforts to address housing needs for its growing urban population. The application and scrutiny of eminent domain in urban development underscore the balance between government initiatives to remedy social issues and the protection of private property rights, as enshrined in the Philippine Constitution and detailed in subsequent laws like the Urban Development Housing Act of 1992.
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