ALEJANDRO MANOSCA v. CA

## FACTS:

Petitioners inherited a piece of land in Calzada, Taguig, Metro Manila, which was declared a national historical landmark by the National Historical Institute (NHI) due to its association with Felix Y. Manalo, the founder of Iglesia Ni Cristo. The NHI issued a resolution declaring the land as a national historical landmark, which was approved by the Minister of Education, Culture and Sports. The Secretary of Justice also opined that the birthsite of Felix Y. Manalo, who made contributions to Philippine history and culture, could be considered a national landmark.

Based on these declarations, the Republic, through the Office of the Solicitor-General, filed a complaint for expropriation in behalf of the NHI, alleging that the land is needed as a national historical landmark for a public purpose. The trial court issued an order allowing the Republic to take immediate possession of the property. However, the petitioners moved to dismiss the complaint, arguing that the expropriation was not for a public purpose and would indirectly benefit the religious entity "Iglesia ni Cristo."

The trial court denied the motion to dismiss, and the Court of Appeals dismissed the petition for certiorari and prohibition filed by the petitioners.

ISSUES

  1. Whether the "public use" requirement of Eminent Domain is satisfied in the attempted expropriation by the Republic of a 492-square-meter parcel of land declared by the National Historical Institute (NHI) as a national historical landmark.

  2. Whether the petitioners have been denied due process in the fixing of the provisional value of their property.

RULING

  1. The Supreme Court ruled that the "public use" requirement is satisfied. It declared that "public use" must be considered in its general concept of meeting a public need or a public exigency. The Court noted that the setting up of a marker to recognize the contributions of Felix Manalo to the Philippines' culture constitutes a public use. The fact that members of the Iglesia ni Cristo might derive more benefit from the expropriation does not detract from its public character, as any peculiar advantage to them is incidental.

  2. Regarding due process in the fixing of the provisional value of the property, the Supreme Court found no denial of due process. The Court highlighted that due process primarily requires an opportunity to be heard, and the records indicated the availability of such an opportunity through various pleadings. Therefore, the claim of denial of due process was unfounded, and the trial court's actions were upheld.

PRINCIPLES

  1. Public Use in Eminent Domain: Eminent domain allows the state to expropriate private property for public use if it meets a public need or exigency. The definition of "public use" is broad, including any beneficial employment for community welfare, not restricted solely to physical use by the public.

  2. Adaptability of Public Use Concept: The concept of "public use" evolves with societal changes, including advancements and changing governmental roles, and is not limited to traditional uses like roads or parks.

  3. Due Process in Eminent Domain: Due process in the context of eminent domain focuses on the opportunity to be heard concerning the valuation and expropriation of property, rather than on the outcomes of such processes.

  4. Incidental Benefits: In eminent domain, if the primary purpose of the exercise serves a public use, incidental benefits to specific groups do not detract from the public character of the expropriation.

  5. Role of Judiciary in Public Use Determinations: The judiciary does not reassess the determinations made by authorized governmental bodies regarding what constitutes a public use unless there is a clear deviation from legal standards.