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MUNICIPALITY OF SAN JUAN v. CA

FACTS:

On February 17, 1978, President Ferdinand Marcos issued Proclamation No. 1716, reserving certain parcels of land in the Municipality of San Juan for Municipal Government Center Site Purposes. The land was occupied by squatters, so the Municipality of San Juan purchased a different land in Taytay, Rizal as a resettlement center for the squatters. The municipality planned to develop its government center on the reserved land after resettling the squatters.

The Municipality of San Juan began developing its government center by constructing various buildings on the land, including the INP Building (now PNP Headquarters), the Fire Station Headquarters, the Municipal Trial Courts, and the Municipal Prosecutors’ Office. On October 6, 1987, President Corazon Aquino issued Proclamation No. 164, amending Proclamation No. 1716. The amendatory proclamation excluded certain parcels of land not being utilized for government center purposes but occupied for residential purposes, and declared them open to disposition under the Public Land Act.

In June 1988, the Corazon de Jesus Homeowners Association filed a petition for prohibition with the Regional Trial Court of Pasig to enjoin the removal or demolition of houses occupied by its members. The association claimed that the lots they occupied were awarded to them by Proclamation No. 164. However, the trial court dismissed the petition, stating that the property was being utilized by the Municipality of San Juan for government purposes.

The Court of Appeals dismissed the appeal, and its decision became final in 1992. Despite this, the homeowners association submitted consolidation-subdivision plans to the Department of Environment and Natural Resources (DENR) for their application under Proclamation No. 164. The Municipality of San Juan filed a petition for prohibition to prevent DENR from issuing any grants to the homeowners association.

ISSUES:

  1. Whether or not Proclamation No. 164 effectively excluded the lots occupied by private respondents from the operation of Proclamation No. 1716.

  2. Whether or not private respondents are entitled to a grant of the land under Proclamation No. 164.

RULING:

  1. Yes, Proclamation No. 164 effectively excluded the lots occupied by private respondents from the operation of Proclamation No. 1716. The Court held that the amendatory proclamation specifically excluded from its operation the parcels of land not being utilized for government center site purposes but actually occupied for residential purposes. As such, private respondents' claim to the land is valid under Proclamation No. 164.

  2. No, private respondents are not entitled to a grant of the land under Proclamation No. 164. The Court ruled that the requirement for the land to be open to disposition under the provisions of the Public Land Act, as amended, was not fulfilled. The Court noted that at the time private respondents submitted their consolidation-subdivision plans to the Department of Environment and Natural Resources (DENR), the land was still being utilized by the Municipality of San Juan for government purposes. Therefore, private respondents cannot be granted ownership or possession of the land.

PRINCIPLES:

  • A proclamation amending a previous proclamation can effectively exclude certain parcels of land from the operation of the original proclamation.

  • For land to be open to disposition under the Public Land Act, as amended, it must not be utilized for government purposes.