Filstream v CA

1936

FILSTREAM v. CA G.R. No. 125128 January 23, 1998 Art. XIII,  1! "r#an Lan$ R%&or' an$ (ou)*n+ FACTS Petitioner, Filstream International, Inc., is the registered owner of the properties subject of this dispute consisting of adjacent parcels of land situated in Antonio Rivera Street, Tondo II, anila, with a total area of !,"#$.$% s&uare meters and covered b' T.(.T. )os. *%!+!#, *%!+!, $+$+-, $+$++, $+*%% and $+*%* of the Register of eeds of anila. /n 0anuar' #, $++!, petitioner filed an ejectment suit before the etropolitan Trial (ourt of anila 12ranch $"3 against the occupants of the abovementioned parcels of on the grounds of  termination of the lease contract and non4pa'ment of rentals. 0udgment was rendered b' the T( on September September $5, $++! ordering private private respondents respondents to vacate the premises and pa' bac6  rentals to petitioner. )ot satisfied, private respondents appealed the decision to the Regional Trial (ourt of anila, which in turn affirmed the decision of the T( in its decision dated Februar' **, $++5. Still not content, private respondents proceeded to the (ourt of Appeals via a petition for review. The result however remained the same as the (A affirmed the decision of the RT( in its decision dated August *", $++5.* Thereafter, no further action was ta6en b' the private respondents, as a result of which the decision in the ejectment suit became final and e7ecutor'. 8owever, it appeared that during the pendenc' of the ejectment proceedings private respondents filed on a' *", $++!, a complaint for Annulment of eed of 97change against  petitioner Filstream which was doc6eted before the RT( RT( of anila. It was at this stage that respondent (it' of anila came into the picture when the cit' government approved /rdinance  )o. #-$!! on )ovember ", $++!, authori:ing a'or Alfredo S. ;im to initiate the ac&uisition b' negotiation, e7propriation, purchase, or other legal means certain parcels of land which formed  part of the properties of petitioner then occupied b' private respondents. Subse&uentl', the (it' of anila approved /rdinance )o. #-""5 declaring the e7propriation of certain parcels of land situated along Antonio Rivera and Fernando a. motion, the RT( of anila issued a TR/ enjoining the e7ecution of the writ. /n appeal to (A, the TR/ was sustained. 8ence this petition for certiorari. ISS"E $. @hether the dismissal of petitioner>s appeal in the e7propriation proceedings based on purel'  procedural and technical grounds is tantamount to a deprivation of propert' without due  process of law 1(A dismissed the petition for non4compliance with Sec. *1a3 of Rule  of the Revised Internal Rules of the (ourt of Appeals b' failing to attach to its petition other   pertinent documents and papers and for attaching copies of pleadings which are blurred and unreadable3 *. @hether the (it' of anila validl' e7propriated petitioner FilstreamDs properties R"LING $. E9S. A strict adherence to the technical and procedural rules in this case would defeat rather  than meet the ends of justice as it would result in the violation of the substantial rights of   petitioner. At sta6e in the appeal filed b' petitioner before the (A is the e7ercise of their propert' rights over the disputed premises which have been e7propriated and have in fact been ordered condemned in favor of the (it' of anila. In effect, the dismissal of their appeal in the e7propriation proceedings based on the aforementioned grounds is tantamount to a deprivation of   propert' without due process of law as it would automaticall' validate the e7propriation  proceedings which the petitioner is still disputing. It must be emphasi:ed that where substantial rights are affected, as in this case, the stringent application of procedural rules ma' be rela7ed if  onl' to meet the ends of substantial justice. *. )/. The (ourt found nothing that would indicate that respondent (it' of anila complied with Sec. + and Sec. $% of R.A. #*#+. Petitioner FilstreamDs properties were e7propriated and ordered condemned in favor of the (it' of anila sans an' showing that resort to the ac&uisition of other  lands listed under Sec. + of RA #*#+ have proved futile. 9videntl', there was a violation of   petitioner FilstreamDs right to due process which must accordingl' be rectified. Indeed, it must be emphasi:ed that the State has a paramount interest in e7ercising its  power of eminent domain for the general good considering that the right of the State to e7propriate private propert' as long as it is for public use alwa's ta6es precedence over the interest of private propert' owners. 8owever we must not lose sight of the fact that the individual rights affected b' the e7ercise of such right are also entitled to protection, bearing in mind that the e7ercise of this superior right cannot override the guarantee of due process e7tended b' the law to owners of the propert' to be e7propriated. In this regard, vigilance over  compliance with the due process re&uirements is in order. @e ta6e judicial notice of the fact that urban land reform has become a paramount tas6 in view of the acute shortage of decent housing in urban areas particularl' in etro anila.  )evertheless, despite the e7istence of a serious dilemma, local government units are not given an unbridled authorit' when e7ercising their power of eminent domain in pursuit of solutions to these problems. The basic rules still have to be followed, which are as follows no person shall  be deprived of life, libert', or propert' without due process of law, nor shall an' person be denied the e&ual protection of the lawsB private propert' shall not be ta6en for public use without

Prepared b' ar' ;ouise . Ramos

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1936

 just compensation 1Art. !, Section +, $+-# (onstitution3.G Thus, the e7ercise b' local government units of the power of eminent domain is not without limitations.

Prepared b' ar' ;ouise . Ramos

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