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PROVINCE OF CAMARINES SUR v. CA

FACTS:

The case involves an appeal from the decision of the Court of Appeals regarding the expropriation of agricultural lands by the Province of Camarines Sur. The Sangguniang Panlalawigan of the province passed a resolution authorizing the purchase or expropriation of property contiguous to the provincial capitol site in order to establish a pilot farm and a housing project for provincial government employees. The resolution stated that the province had adopted a comprehensive development plan which included the establishment of a model and pilot farm for non-food and non-traditional agricultural crops.

The Province of Camarines Sur filed two cases for expropriation against the San Joaquin family, seeking possession of their property. The San Joaquins moved to dismiss the complaints on the ground of inadequacy of the price offered. However, the trial court denied the motion and authorized the Province to take possession of the property. The San Joaquins filed a motion for relief, which was denied. They then filed a petition before the Court of Appeals, seeking the nullification of the resolution, dismissal of the complaints, and setting aside of the orders issued by the trial court.

The Court of Appeals set aside the orders and ordered the suspension of the expropriation proceedings until the Province obtains the approval of the Department of Agrarian Reform to convert the classification of the lands from agricultural to non-agricultural use. The petitioners then filed an appeal before the Supreme Court.

ISSUES:

  1. Whether the expropriation of the property satisfies the constitutional requirement of "public use".

  2. Whether the Province of Camarines Sur must comply with the provision of Section 65 of the Comprehensive Agrarian Reform Law and secure the approval of the Department of Agrarian Reform before expropriating the lands.

  3. Whether the Department of Agrarian Reform has the authority to determine the suitability of agricultural land for expropriation purposes.

  4. Whether the local government units are required to obtain approval from the Department of Agrarian Reform for the conversion of agricultural land to non-agricultural use in expropriation cases.

RULING:

  1. The establishment of a pilot development center and a housing project satisfy the public purpose requirement of the Constitution as they contribute to the general welfare and the prosperity of the whole community. Therefore, the expropriation of the property is for a public purpose.

  2. The provision of Section 65 of the Comprehensive Agrarian Reform Law does not apply to the expropriation of agricultural lands by local government units. To require the approval of the Department of Agrarian Reform for the conversion of lands would be beyond the scope of the authority granted to local government units under the Local Government Code.

  3. The Department of Agrarian Reform does not have the authority to determine the suitability of agricultural land for expropriation purposes. The exclusive authority of the Department of Agrarian Reform is limited to the approval or disapproval of conversions of agricultural lands for residential, commercial, or industrial uses when applications for reclassification are submitted by the landowners or tenant beneficiaries.

  4. Local government units are not required to obtain approval from the Department of Agrarian Reform for the conversion of agricultural land to non-agricultural use in expropriation cases. It is the legislative branch of the local government unit that determines whether the use of the property sought to be expropriated is for a public purpose, and the courts only intervene when the particular undertaking has no real or substantial relation to the public use.

PRINCIPLES:

  • The concept of "public use" in the Constitution means public advantage, convenience, or benefit that contributes to the general welfare and the prosperity of the whole community.

  • Housing is a basic human need and the shortage in housing is a matter of state concern that affects public health, safety, the environment, and the general welfare.

  • Local government units can exercise the power of eminent domain only when expressly authorized by the legislature.

  • The limitations on the exercise of the delegated power of eminent domain must be clearly expressed in the law conferring the power or in other legislations.

  • The provision of Section 65 of the Comprehensive Agrarian Reform Law applies to lands previously placed under the agrarian reform program and not to the expropriation of agricultural lands by local government units.

  • Statutes conferring the power of eminent domain to political subdivisions cannot be broadened or constricted by implication.

  • The Republic of the Philippines, as sovereign, or its political subdivisions, cannot be bound by provisions of law couched in general terms.

  • The valuation for just compensation in expropriation cases should be determined based on the rules laid down in Rule 67 of the Rules of Court, allowing private respondents to present evidence for the just compensation of their property.