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San Juan v. Court of Appeals

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San Juan v. Court of Appeals

Case Title and Citation

Municipality of San Juan, Metro Manila, petitioner, vs. Court of Appeals, Department of Environment and Natural Resources, Corazon de Jesus Homeowners Association, Inc., et al., respondents.
G.R. No. 125183, September 29, 1997
Supreme Court - Third Division
Ponente: Justice Melo

Facts

  • February 17, 1978: President Marcos issued Proclamation No. 1716, reserving for Municipal Government Center Site Purposes certain parcels of land of the public domain in the Municipality of San Juan, Metro Manila.
  • The land covered by Proclamation No. 1716 was occupied by squatters; the Municipality of San Juan purchased an 18-hectare parcel in Taytay, Rizal, as a resettlement center for those squatters. After resettlement, the municipality began developing its government center, constructing the INP Building (now housing the PNP Headquarters, Fire Station, and two Municipal Trial Court salas), the Central Post Office Building, and the Municipal High School Annex Building.
  • October 6, 1987: President Aquino issued Proclamation No. 164 amending Proclamation No. 1716, excluding from operation parcels not being utilized for government center purposes but actually occupied for residential purposes, and declaring the land open to disposition under the Public Land Act, as amended, subject to future survey. The description included parcels such as Lot 1 (Port.) Psu-73270, Lot 4 (Port.) Psd-740 and Psd-810, Lot 5 (Port.) Psu-73270, among others.
  • June 1, 1988: Corazon de Jesus Homeowners Association, Inc. (private respondents) filed with the RTC a petition for prohibition with urgent prayer for restraining order against the Municipal Mayor, the Municipal Engineer, and the Curator of Pinaglabanan Shrine, to prevent removal or demolition of houses of association members allegedly awarded under Proclamation No. 164.
  • September 14, 1990: RTC dismissed the petition, ruling the land was being used by the Municipality for government purposes and thus the condition in Proclamation No. 164 was absent.
  • July 17, 1991: CA decision dismissed the appeal; the judgment became final and was entered on April 8, 1992.
  • Thereafter, private respondents pursued consolidation-subdivision plans and submitted them to DENR for a grant under Proclamation No. 164. The Municipality filed a petition for prohibition with TRO and preliminary injunction against DENR and private respondents.
  • RTC sustained the Municipality and enjoined DENR from disposing and awarding parcels of land covered by Proclamation No. 164. CA reversed.
  • The central issue concerns the interpretation of Proclamation No. 164 in relation to Proclamation No. 1716, and whether the earlier final judgment on Proclamation No. 164 bars subsequent action (res judicata). The Court ultimately held Proclamation No. 164 to be an invalid exercise of legislative power and void, with consequences for DENR’s ability to grant dispositions under that proclamation.

Issues

  1. Proclamation No. 164 validly amended Proclamation No. 1716 and is enforceable.
  2. Proclamation No. 164 was validly issued as a legislative act, or, put differently, is not void for usurping legislative power.
  3. Whether res judicata applies to the area of land covered by Proclamation No. 164 as determined in the prior case.

Ruling

  1. No — Proclamation No. 164 is not a valid and enforceable amendment; it is an invalid exercise of legislative power. The proclamation was issued during a period when Congress held legislative power, and an executive proclamation attempting to amend Proclamation No. 1716 was unauthorized.
  2. Yes — There is res judicata as to the portion of land covered by Proclamation No. 164 that was the subject of the earlier case; the elements of res judicata (finality of judgment, jurisdiction, on the merits, and identity of parties, subject matter, and cause of action) are satisfied for that portion.
  3. (Addressed within the reasoning) The court ultimately sets aside the CA decision and enjoins DENR from enforcing Proclamation No. 164.

Reasoning / Ratio Decidendi

  • Proclamation No. 1716, issued by Marcos, was a valid act of legislation. Proclamation No. 164, issued by Aquino, purporting to amend 1716, was not a valid legislative act because, following the 1986 revolution, the President lacked legislative power under the Freedom Constitution until a new constitution and legislative body were formed. The Court cites the separation of powers and the principle that an executive act cannot validly amend a statute framed by the legislature. See Salas v. Jarencio; Peralta v. Comelec; and the general presumption of validity of statutes absent an unlawful usurpation.
  • The Court notes the long-standing presumption that statutes are valid, but this presumption does not apply where there is clear usurpation of legislative power by the executive branch. This necessitates declaring Proclamation No. 164 null and void.
  • Re res judicata, the Court recalls the basic elements: (a) final judgment; (b) court’s jurisdiction; (c) judgment on the merits; and (d) identity of parties, subject matter, and cause of action. The Court determines there is identity and the area covered by Proclamation No. 164 that was litigated in the prior case remains subject to res judicata. See Mangoma v. Court of Appeals; Suarez v. Municipality of Naujan.
  • The Court’s ultimate disposition is grounded in the constitutional violation of usurpation, overriding the CA’s ruling, while recognizing a limited res judicata effect for the portion of land previously adjudicated.

Doctrine / Legal Principle

  • Separation of powers and checks on executive action.
  • Usurpation of legislative power invalidates an executive proclamation.
  • Presumption of validity applies only to validly enacted statutes; no presumption can sustain an invalid act.
  • Res judicata requires final judgment, jurisdiction, on the merits, and identity of parties, subject matter, and cause of action; its reach may be limited to the specific area adjudicated.

Disposition

  • The appealed decision of the Court of Appeals is SET ASIDE. DENR is permanently enjoined from enforcing Proclamation No. 164. The proclamation is declared null and void, as an invalid exercise of legislative power. The petition is granted to the extent of voiding Proclamation No. 164 and preventing its enforcement.

Concurring / Dissenting Opinions

  • Concurrence: Chief Justice Narvasa, and Justices Romero, Francisco, and Panganiban concurred with the decision.

Significance / Notes

  • Reaffirms that proclamations amending land-disposition schemes must derive from valid legislative authority; executive issuances cannot substitute for or amend valid proclamations absent proper legislative action.
  • Clarifies the interaction between res judicata and later constitutional challenges; while res judicata can apply to the specific area litigated, it does not validate an otherwise unconstitutional act.
  • Impacts government center land disputes, particularly where residential occupancy and government-site designations intersect with public land dispositions.
Property Law Administrative Law Constitutional Law Remedial Law Civil Procedure
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