Manosca v. CA (G.R. No. 106440; January 29, 1996)
FACTS:
ISSUE: What is the so-called unusual interest that the expropriation of (Felix Manalos) birthplace become so vital as to be a public use appropriate for the exercise of the power of eminent domain when only members of the Iglesia ni Cristo would benefit?
RULING:
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SYLLABUS
1. POLITICAL LAW; INHERENT POWER OF THE STATE; EMINENT DOMAIN; CONCEPT. - Eminent domain, also often referred to as expropriation and, with less frequency, as condemnation, is, like police power and taxation, an inherent power of sovereignty. It need not be clothed with any constitutional gear to exist; instead, provisions in our Constitution on the subject are meant more to regulate, rather than to grant, the exercise of the power. Eminent domain is generally so described as the highest and most exact idea of property remaining in the government that may be acquired for some public purpose through a method in the nature of a forced purchase by the State. It is a right to take or reassert dominion over property within the state for public use or to meet a public exigency. It is said to be an essential part of governance even in its most primitive form and thus inseparable from sovereignty. The only direct constitutional qualification is that private property shall not be taken for public use without just compensation. This proscription is intended to provide a safeguard against possible abuse and so to protect as well the individual against whose property the power is sought to be enforced.
2. ID.; ID.; ID.; THE GUIDELINES SET BY THE SUPREME COURT IN GUIDO VS. RURAL PROGRESS ADMINISTRATION WHERE NOT MEANT TO BE PRECLUSIVE IN NATURE AND THE POWER OF EMINENT DOMAIN SHOULD NOT BE UNDERSTOOD AS BEING CONFINED ONLY TO EXPROPRIATION OF VAST TRACTS OF LAND AND LANDED ESTATES. - The court, in Guido, merely passed upon the issue of the extent of the Presidents power under Commonwealth Act No. 539 to, specifically, acquire private lands for subdivision into smaller home lots or farms for resale to bona fide tenants or occupants. It was in this particular context of the statute that the Court had made the pronouncement. The guidelines in Guido were not meant to be preclusive in nature and, most certainly, the power of eminent domain should not now be understood as being confined only to the expropriation of vast tracts of land and landed estates.
3. ID.; ID.; ID.; TRADITIONAL CONCEPT OF PUBLIC USE EXPANDED. - The validity of the exercise of the power of eminent domain for traditional purposes is beyond question; it is not at all to be said, however, that public use should thereby be restricted to such traditional uses. The idea that public use is strictly limited to clear cases of use by the public has long been discarded.
4. ID.; ID.; ID.; SIGNIFICANT FACTOR TO BE CON-SIDERED IN EMINENT DOMAIN IS THE PRINCIPAL OBJECTIVE OF THE EXERCISE OF THE POWER AND NOT THE CASUAL CONSEQUENCES THAT MIGHT FOLLOW FROM SUCH EXERCISE. - The attempt to give some religious perspective to the case deserves little consideration, for what should be significant is the principal objective of, not the casual consequences that might follow from the exercise of the power. The purpose in setting up the marker is essentially to recognize the distinctive contribution of the late Felix Manalo to the culture of the Philippines, rather than to commemorate his founding and leadership of the Iglesia ni Cristo. The practical reality that greater benefit may be derived by members of the Iglesia ni Cristo than by most others could well be true but such a peculiar advantage still remains to be merely incidental and secondary in nature. Indeed, that only a few would actually benefit from the expropriation of property does not necessarily diminish the essence and character of public use.
