G.R. No.

106440

January 29, 1996

ALEJANDRO MANOSCA, ASUNCION MANOSCA and LEONICA MANOSCA, petitioners,

vs.
HON. COURT OF APPEALS, HON. BENJAMIN V. PELAYO, Presiding Judge, RTC-Pasig,
Metro Manila, Branch 168, HON. GRADUACION A. REYES CLARAVAL, Presiding Judge,
RTC-Pasig, Metro Manila, Branch 71, and REPUBLIC OF THE PHILIPPINES, respondents.
Facts: Petitioners inherited a piece of land in P. Burgos street, taguig, metro manila.
The National History institute declared said inherited land as a national historical
landmark since it was discovered that it was the birthplace of Felix manalo, the
founder of Iglesia ni cristo. An expropriation proceeding was made and the
petitioner moved to dismiss the case since the expropriation would only benefit
members of the INC. That the expropriation of which would tantamount to use of
public funds to the benefit of a religious entitiy which would be contrary to the
proper use of public funds.
Issue: WON the expropriation is within the ambit of public use.
Held: The court ruled that the same is for public use. The law recognizes the
contribution of Felix Manalo to the culture of the Philippines. The fact that he was
the founder of Iglesia ni Cristo is given little weight. Even if it would benefit greatly
to the members there of, the primary objective and purpose is to recognize his
notable contributions. Him being the founder thereof is merely incidental and
secondary to the purpose.

G.R. No. 137285

January 16, 2001

ESTATE SALUD JIMENEZ, petitioner,

vs.
PHILIPPINES EXPORT PROCESSING ZONE, respondent.
Facts: The Philippine export processing zone initiated an expropriation proceeding
against the estate of the petitioner which was located in cavite. 10 years after, the
land was expropriated which benefited Philippine Vinyl Corporation. The petitioner
contested the validity of this since Philippine Vinyl corporation is a private
corporation hence the appropriation was not for a public purpose.
Issue: WON the expropriation is for public use even if it would inure to the benefit of
a private entity.
Held: Petition is denied. The court ruled that expropriation is for public use. The land
in issue was expropriated "for the constructionof terminal facilities, structures and approaches
thereto." The authority is broad enough to give the respondent substantial leeway in deciding for
what public use the expropriated property would be utilized. Pursuant to this broad authority,
respondent leased a portion of the lot to commercial banks while the rest was made a
transportation terminal. The public use requirement must be construed in a more
comprehensive manner so that indirect benefit or advantage would suffice the public use.

G.R. No. 147511

January 20, 2003

MARINA Z. REYES; ALFREDO A. FRANCISCO; ANGELITA Z. GARCIA; ALFREDO Z.

FRANCISCO, JR; ARMANDO Z. FRANCISCO; ALMA C. FRANCISCO; EUGENIA Z. LUNA;
CLARITA Z. ZABALLERO, LEONARDO Z. ZABALLERO, JR, and TEODORO Z.
ZABALLERO, in substitution of LEONARDO M. ZABALLERO; AUGUSTO M. ZABALLERO;
FRINE A. ZABALLERO; ELENA FRONDA ZABALLERO; VICTOR GREGORIO F.
ZABALLERO; MARIA ELENA F. ZABALLERO; LOURDES ZABALLERO-LAVA; SOCORRO
EMILIA ZABALLERO-YAP; and TERESITA F. ZABALLERO, petitioners,
vs.
NATIONAL HOUSING AUTHORITY, respondent.
Facts: Respondent in this case initiated expropriation proceedings against the
properties of the petitioners. The purpose of which is to construct a resettlement
area to the benefit of informal settlers residing in metro manila. The expropriation
was accorded to by law and just compensation was awarded to the petitioners.
Years later, petitioners contested the expropriation laying the basis that the
respondent has failed to comply with the requirement of having the squatters of
Metro manila to resettle in said housing projects. An ocular inspection was made
and it was proven that majority of the houses were unoccupied. Petitioners claimed
that since public use of the same was not achieved and the land should be returned
to them.
Issue: WON public use is forfeited when the same is not achieved.
Held: The court ruled in favor of the respondents. The term Public use must be
given a broader meaning and should not be strictly construed with. Its meaning
must be made synonymous to public welfare, public interest and public benefit. It
would not matter if the land is sold to private home owners of private concerns as
long as it is for the common good and to the furtherance of cost efficient housing
projects.