### Facts:
1. **Proclamation No. 1716 (1978)**: President Ferdinand Marcos issued Proclamation No. 1716, reserving certain parcels of public land in San Juan, Metro Manila for municipal government center purposes.
2. **Resettlement Efforts**: The Municipality of San Juan bought 18 hectares in Taytay, Rizal to resettle squatters occupying the proclaimed lands. Post-resettlement, the municipality developed the land, constructing various government buildings.
3. **Proclamation No. 164 (1987)**: After Congress convened, President Corazon Aquino issued Proclamation No. 164, amending Proclamation No. 1716 to exclude parcels used for residential purposes and opened them for disposition under the Public Land Act.
4. **Legal Dispute Initiation (1988)**: Corazon de Jesus Homeowners Association filed a petition for prohibition to prevent the demolition of their houses, claiming Proclamation No. 164 awarded them the land.
5. **Regional Trial Court Ruling (1990)**: The court dismissed the petition, stating the municipality was using the land for government purposes, and the condition of Proclamation No. 164 was not met.
6. **Court of Appeals Decision (1991)**: The decision was appealed but dismissed, and became final on April 8, 1992.
7. **Respondents’ Actions**: The respondents hired a surveyor and submitted plans to the DENR, seeking land grants under Proclamation No. 164.
8. **Municipality’s Response**: The Municipality filed a petition for prohibition to stop the DENR from granting the land to the respondents, which was initially upheld by the RTC.
9. **Court of Appeals Reversal (1995)**: The RTC’s decision was reversed by the Court of Appeals. This led the Municipality to file a petition for review with the Supreme Court.
10. **Supreme Court Petition**: The case brought before the Supreme Court challenged the interpretations of Proclamation Nos. 1716 and 164 and the application of the doctrine of res judicata.
### Issues:
1. **Validity of Proclamation No. 164**: Was Proclamation No. 164, issued by President Aquino, a valid exercise of legislative power?
2. **Application of Res Judicata**: Does the doctrine of res judicata apply to bar any further claims by the respondents over the land in question?
### Court’s Decision:
1. **Proclamation No. 164’s Validity**:
– **Supreme Court Ruling**: The Court ruled that Proclamation No. 164 was issued after Congress convened and was, therefore, an invalid exercise of legislative power, as President Aquino no longer held legislative powers.
– **Legal Basis**: The separation of powers doctrine was cited, emphasizing the illicit nature of the executive’s usurpation of legislative powers.
2. **Res Judicata Application**:
– **Supreme Court’s Application**: The Court agreed that res judicata applied concerning the land covered by Proclamation No. 164 already subject to final judgment.
– **Elements Met**: The earlier judgment was final, issued by a court with jurisdiction, was on the merits, and the second case had the same parties, subject matter, and cause of action.
### Doctrine:
1. **Separation of Powers**: Legislative powers can only be exercised by the legislative body unless exceptions exist; unauthorized executive actions infringing on legislative authority are null and void.
2. **Res Judicata**: A matter that has been adjudicated by a competent court and therefore may not be pursued further by the same parties.
### Class Notes:
1. **Separation of Powers**: Crucial for maintaining checks and balances among government branches. Post-convening of Congress, the President cannot exercise legislative powers.
– **Art. VI, Sec. 1 of the 1987 Constitution**: “The legislative power shall be vested in the Congress of the Philippines.”
– **Case Application**: The Court invalidated Proclamation No. 164, emphasizing executive overreach.
2. **Res Judicata Elements**:
– Final judgment
– Jurisdiction over the parties and subject matter
– Decision on the merits
– Identity of parties, subject matter, and cause of action
– **Case Reference**: Elements were verified in Municipality of San Juan vs. Corazon De Jesus Homeowners Association to bar repetitive litigation.
### Historical Background:
– **Martial Law and Its Aftermath**: Proclamation No. 1716 (1978) under Marcos’ regime was during Martial Law, allowing legislative power concentration in the executive through Amendment No. 6.
– **Post-EDSA Revolution Period**: Proclamation No. 164 (1987) arose during post-Marcos political restructuring, under President Aquino’s transitional government moving towards renewed democratic institutions.
– **Constitutional Transition**: The case illustrates the transition from martial law decrees to democratic legislative processes, highlighting the importance of constitutional adherence during executive and legislative power shifts.
Leave a Reply