**Facts:**
1. Justa G. Guido owned two adjoining lots, part commercial, with a combined area of 22,655 square meters in Maypajo, Caloocan, Rizal.
2. The Rural Progress Administration (RPA) filed a complaint for the expropriation of Guido’s land to subdivide it for sale to bona fide tenants or occupants, or individuals who would work the lands as per Commonwealth Act No. 539.
3. Guido contested the expropriation on several grounds, including that RPA lacked jurisdiction, the land was commercial property, existing tenant agreements would be impaired, and the provisional value set for the land was inadequate.
4. Following conflicting decisions in lower courts, Guido filed a petition for prohibition in the Supreme Court to prevent the expropriation.
**Issues:**
1. Did the RPA act within its jurisdiction and corporate powers in filing the expropriation complaint and negotiating a loan?
2. Is commercial land excluded from the scope of the provisions of Act No. 539?
3. Would the expropriation impair existing contracts with tenants?
4. Was the provisional value of the land correctly determined?
**Court’s Decision:**
The Supreme Court addressed primarily whether the expropriation of commercial property falls within the scope of Act No. 539. The opinion by Justice Tuason articulated:
1. The constitutional and statutory provisions aim to address social justice concerns, particularly regarding agrarian reforms, by breaking up large estates for redistribution to tenant-dwellers.
2. The framers of the Constitution did not intend for this power to be used for expropriating small, urban, commercial properties.
3. The expropriation of Guido’s land did not serve a public purpose or public benefit as required by law. It was designed to benefit a few tenants without any broader public health, peace, or economic considerations.
4. The expropriation of commercial land does not comply with the constitutional mandate under Section 4, Article XIII, since it does not correct the specific social inequities contemplated by the law.
5. Therefore, the petition for prohibition was granted, halting the expropriation proceedings.
**Doctrine:**
1. **Public Use Doctrine in Expropriation:** Expropriation must serve a significant public benefit. Small property expropriations benefiting limited private individuals without broader public interest are unconstitutional.
2. **Social Justice and Agrarian Reforms:** Constitutional provisions for expropriation primarily address large estates to alleviate agrarian issues, not minor urban properties.
3. **Restrictions on Governmental Expropriation Powers:** The government cannot expropriate property merely to transfer its benefits to new private owners without clear public utility.
**Class Notes:**
1. **Public Use Requirement:** Expropriation must aim to provide significant public benefits, not mere private gains.
2. **Scope of Agrarian Reforms:** The expropriation mandate under social justice pertains to large rural estates tied to agrarian issues.
3. **Just Compensation and Public Benefit:** Government expropriation should ensure just compensation and an overarching public benefit.
**Historical Background:**
The ruling comes at the backdrop of post-war Philippines where land reforms were crucial to address tenant-landlord conflicts and large estate monopolies. Commonwealth Act No. 539 was part of broader agrarian reform legislation aimed at promoting social and economic justice by breaking up large estates. The Supreme Court’s decision illustrates the limits of this legislation, ensuring that it aligns with the specific intent to address rural and agrarian concerns, not extending to urban commercial properties.
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