AI-generated
Updated 18th February 2025
DPWH vs. Manalo
This case concerns the rights of informal settlers facing eviction due to a government infrastructure project. The Supreme Court affirmed the lower courts' decisions, holding that the Department of Public Works and Highways (DPWH) must comply with due process and the requirements of existing laws before evicting the respondents and demolishing their structures.

Primary Holding

The Supreme Court held that the DPWH failed to follow the proper procedure for evicting the respondents, who are informal settlers, and that the case should be remanded to the trial court to determine if the respondents are entitled to damages.

Background

The DPWH initiated a C-5 extension project that affected the residential structures of the respondents, who are informal settlers. Instead of initiating expropriation proceedings, the DPWH offered financial assistance, which the respondents deemed insufficient. The respondents filed a complaint seeking just compensation.

History

  • September 13, 2010: Respondents filed a Complaint before the Regional Trial Court of Quezon City.

  • November 15, 2010: Quezon City Task Force issued a Notice of Demolition.

  • January 19, 2011: DPWH filed its Answer praying that the Complaint be dismissed.

  • May 5, 2011: The Regional Trial Court denied the DPWH's prayer to dismiss.

  • June 30, 2011: Regional Trial Court denied the DPWH's Motion for Reconsideration.

  • March 19, 2015: Court of Appeals affirmed the Regional Trial Court's findings.

  • July 5, 2016: Respondents Manalo, et al. filed their Comment.

  • The DPWH then filed a Petition for Review on Certiorari before the Supreme Court.

Facts

  • 1. The respondents were owners of residential structures on land owned by the Metropolitan Waterworks and Sewerage System, which was affected by the DPWH's C-5 extension project. The DPWH offered financial assistance, which the respondents rejected, claiming it was too small. The DPWH argued that the respondents were squatters and not entitled to just compensation, only financial assistance under Republic Act No. 7279.

Arguments of the Petitioners

  • 1. The DPWH argued that the complaint failed to state a cause of action because the respondents were squatters on government-owned land and were only entitled to financial assistance, not just compensation. They also claimed the respondents could be summarily evicted as professional squatters.

Arguments of the Respondents

  • 1. The respondents argued that they owned the structures demolished by the DPWH and were entitled to just compensation or suitable relocation. They asserted the trial court had jurisdiction to determine just compensation.

Issues

  • 1. Whether the Court of Appeals erred in finding that the Regional Trial Court did not gravely abuse its discretion in denying petitioner Department of Public Works and Highways' prayer to dismiss respondents Eddie Manalo, et al.'s Complaint.
  • 2. Whether the petitioner can extrajudicially and summarily evict respondents and demolish their structures.
  • 3. Whether the respondents are entitled to just compensation for their structures.

Ruling

  • 1. The Supreme Court denied the Petition for Review on Certiorari. It ruled that the complaint sufficiently stated a cause of action because the respondents had rights to their structures, the DPWH had an obligation to respect those rights, and the DPWH violated those rights. The Court also held that the DPWH failed to follow the proper procedure for eviction and demolition under Republic Act Nos. 8974 and 7279.

Doctrines

  • 1. Cause of Action: A complaint states a cause of action if it alleges (1) the plaintiff's legal right; (2) the defendant's correlative obligation; and (3) the defendant's act or omission violating the plaintiff's right.
  • 2. Eminent Domain/Expropriation: The State's inherent right to condemn private property for public use with just compensation, complying with specific requisites.
  • 3. Rights of Urban Poor Dwellers: Urban or rural poor dwellers shall not be evicted nor their dwellings demolished, except in accordance with law and in a just and humane manner.

Key Excerpts

  • 1. "The mandate of our Constitution is clear: 'Urban or rural poor dwellers shall not be evicted nor their dwellings demolished, except in accordance with law and in a just and humane manner.'"
  • 2. "Urban or rural poor dwellers shall not be evicted nor their dwellings demolished, except in accordance with law and in a just and humane manner."

Precedents Cited

  • 1. Zuñiga-Santos v. Santos-Gran: Used to define cause of action and the distinction between failure to state a cause of action and lack of cause of action.
  • 2. Heirs of Pamaran v. Bank of Commerce: Used to differentiate between motions to dismiss for failure to state a cause of action and those based on insufficiency of evidence.
  • 3. China Road and Bridge Corporation v. Court of Appeals: Used to support the consideration of pleadings and annexes in determining if a cause of action exists.
  • 4. Aquino v. Quiazon: Used to emphasize that a complaint should not be dismissed if it provides a sufficient basis for the suit, regardless of potential defenses.

Statutory and Constitutional Provisions

  • 1. Philippine Constitution, Article III, Section 9: Private property shall not be taken for public use without just compensation.
  • 2. Philippine Constitution, Article XIII, Section 10: Urban or rural poor dwellers shall not be evicted nor their dwellings demolished, except in accordance with law and in a just and humane manner.
  • 3. Republic Act No. 7279 (Urban Development and Housing Act of 1992), Sections 27, 28, 29: Provisions regarding eviction and demolition procedures, and actions against professional squatters.
  • 4. Republic Act No. 8974, Section 9: Squatter Relocation.
  • 5. Rules of Court, Rule 2, Section 2: Definition of cause of action.