JM Tuason & Co., Inc. v. Land Tenure Administration, G.R. No.

L-21064, February 18,

1970

TOPIC: IV. AIDS IN STATUTORY CONSTRUCTION

A. Public Policy sought to be implemented
D. Extrinsic Aids
b. Explanatory Note of the author/s

FACTS:

 A special civil action for prohibition to nullify a legislative act directing the expropriation
of the tatalon estate, Quezon city.

 On August 3, 1959, republic act 2616 took effect which states that the expropriation of
the tatalon estate which is Jointly owned by our petitioner JM Tuason & Co. and others
is hereby authorized.

 The land involved in this action is registered under the name of the petitioner JM
Tuason

 Land Tenure administration the defendant is the one directed by the executive
secretary to institute the proceeding of the expropriation.

 JM tuazon not losing any time filed before the lower court a special action for
prohibition with preliminary injunction against the respondents praying that the
Legislative act is be declared unconstitutional. Meanwhile a preliminary injunction to
restrain respondents from proceeding to the expropriation of the said property.

 Lower court granted the preliminary injunction and decided that RA 2616 is
unconstitutional granting the writ of prohibition.

ISSUE:
Is RA 2616 is constitutional?

THESIS:

Yes, RA 2616 as amended is valid and constitutional.

RULE:

The title of a statute serves as aid, in case of doubt in its language, to its construction and to
ascertaining legislative will.
ANALYSIS:

In this case, we discover the historical basis of this provision as reflected in the proceedings
of the Constitutional Convention, two of the extrinsic aids to construction along with the
contemporaneous understanding and the consideration of the consequences that flow from the
interpretation under consideration, yields additional light on the matter. The constitutionality of
RA 2616 is valid because the power to exercise expropriation by the congress is given by
the Constitution. The question is one of constitutional construction (of interpreting the
constitution). The task is to ascertain the realization of the purpose of the framers and of
the people in adopting the Constitution. It is assumed that that the words in the constitutional
provisions express the objectivity sought to be attained. They are to be given their ordinary
meaning of the except where technical terms are employed in which case the significance thus
attached to them prevails. The congress has the legislative will to expropriate and subdivide
lands it deems to be fit for sale. Moreover, it cannot be denied that congress has the capacity to
exercise such authority. The language employed is not swathed in obscurity (because congress
has the legislative power as stated in the constitution). It is presumed that the constitution
suffices to govern the life of the people not only at the present time but also in the indefinite
future. The constitution though does not give rigid answers but is flexible and accommodates
the problems the future may pose. The constitution is dynamic in nature and not static. It reflects
the social political environment of the times. It adapts and changes.

CONCLUSION:

Therefore, RA 2616 as amended is valid and constitutional.

FULL TEXT REFERENCE: https://www.chanrobles.com/cralaw/1970februarydecisions.php?

id=46

NOTES:

REPUBLIC ACT No. 2616, AN ACT PROVIDING FOR THE EXPROPRIATION OF THE
TATALON ESTATE IN QUEZON CITY AND FOR THE SALE, AT COST, OF THE LOTS
THEREIN TO THEIR PRESENT BONA FIDE OCCUPANTS, AND AUTHORIZING THE
APPROPRIATION OF TEN MILLION PESOS FOR THE PURPOSE.

 2This does not mean it devoids the character of permanency, which is a distinguishing
mark of a constitution, but that it is of the continuing life of a constitution stressed by the
chief architects, Manuel A. Roxas, later to be the first president of the Republic. It was
his view that the constitution to be adopted by the Constitutional Convention of 1934
would "have an indefinite life, will be permanent, subject of course, to revisions,
amendments and other changes that may be adopted constitutionally." That would be
 an assurance that constitutional guarantees "will be maintained, property rights will be
safeguarded, and individual rights maintained immaculate and sanctified. ..."

 This is not to say of course that property rights are disregarded. This is merely to
emphasize that the philosophy of our Constitution embodying as it does what Justice
Laurel referred to as its "nationalistic and socialist traits discoverable upon even a
sudden dip into a variety of [its] provisions" although not extending as far as the
"destruction or annihilation" of the rights to property. This particular grant of authority to
congress authorizing the expropriation of land is clear manifestation of such policy that
finds expression in our fundamental law and so is the social justice principle enshrined
in the constitution of which is an expression as what Justice Reyes in his dissenting
opinion "The Constitution considered the small individual land tenure to be so important
to the maintenance of peace and order and to the promotion of progress and the
general welfare that it not only provided for the expropriation and subdivision of lands
but also opened the way for the limitation of private landholdings. (Art. XIII, section 3).

 There need be no fear that such constitutional grant of power to expropriate lands is
without limit.  As in the case of the more general provision on eminent domain, there is
the explicit requirement of the payment of Just compensation. It is well-settled that just
compensation means the equivalent for the value of the property at the time of its
taking. Anything beyond that is more, and anything short of that is less, than just
compensation.