Municipality of San Juan vs. Court of Appeals

The President cannot exercise legislative power after Congress has convened under the 1987 Constitution. Because Proclamation No. 164 was issued after the convening of Congress, the Court held that it constituted a clear usurpation of legislative power by the executive branch and was thus null and void, notwithstanding the presumption of validity generally afforded to statutes.

On February 17, 1978, President Ferdinand Marcos issued Proclamation No. 1716, reserving certain parcels of land in the Municipality of San Juan for Municipal Government Center Site Purposes. Because the land was occupied by squatters, the municipality purchased an 18-hectare resettlement site in Taytay, Rizal. After resettling the squatters, the municipality constructed several government facilities on the subject land, including the INP Building, the Fire Station Headquarters, trial court salas, the Office of the Municipal Prosecutors, the Central Post Office, and a high school annex. On October 6, 1987, President Corazon Aquino issued Proclamation No. 164, which amended Proclamation No. 1716 by excluding from its operation parcels not utilized for government center site purposes but actually occupied for residential purposes, and declaring the excluded land open to disposition under the Public Land Act.

• Proclamation No. 1716: President Marcos issued Proclamation No. 1716 on February 17, 1978, pursuant to Amendment No. 6, reserving public land in San Juan for a municipal government center.
• Municipal Development: The Municipality of San Juan purchased an 18-hectare resettlement site in Taytay, Rizal, to relocate squatters from the reserved land. Following the resettlement, the municipality constructed multiple government buildings on the site, including police headquarters, a fire station, court salas, a prosecutor's office, a post office, and a high school annex.
• Proclamation No. 164: On October 6, 1987, President Aquino issued Proclamation No. 164, which amended Proclamation No. 1716 by excluding parcels not utilized for government center purposes but occupied for residential purposes, and opening them to disposition under the Public Land Act.
• First Prohibition Case: On June 1, 1988, the Corazon de Jesus Homeowners Association, Inc. filed a petition for prohibition in the RTC to enjoin the demolition of their houses, claiming rights under Proclamation No. 164. The RTC dismissed the petition on September 14, 1990, finding that the property was being utilized for government purposes, thereby negating the condition for exclusion under Proclamation No. 164. The CA dismissed the appeal on July 17, 1991, and the judgment became final on April 8, 1992.
• Second Prohibition Case: Private respondents subsequently hired a private surveyor and submitted consolidation-subdivision plans to the DENR to apply for a land grant under Proclamation No. 164. To prevent the DENR from issuing any grant, the municipality filed a second petition for prohibition with the RTC, which granted the injunction. The CA reversed, prompting the present petition.

• Petitioner maintained that res judicata applies because a prior final judgment had already settled the respective rights of the parties under Proclamation No. 164.
• Petitioner argued that the municipality's rights over the subject property against the claims of private respondents had been previously upheld and should be respected.

• Respondent countered that res judicata did not apply, asserting that the DENR, a new party, was included in the second case.
• Respondent argued that Proclamation No. 164 validly excluded the residentially occupied lands from the government center site, entitling the occupants to apply for land grants.

• Procedural Issues:
  • Whether the principle of res judicata bars the second action involving the land covered by Proclamation No. 164.
• Substantive Issues:
  • Whether President Aquino validly exercised legislative power in issuing Proclamation No. 164 on October 6, 1987, after Congress had convened on July 26, 1987.

• Procedural: The Court held that res judicata applies to the specific area covered by Proclamation No. 164 that was the subject of the earlier case. The Court found that all the elements of res judicata were present: (a) the former judgment was final; (b) the court had jurisdiction; (c) it was a judgment on the merits; and (d) there was identity of parties, subject matter, and cause of action. The Court ruled that substantial, not absolute, identity of parties is sufficient; thus, the addition of the DENR in the second case did not negate the identity of parties. However, res judicata does not extend to portions outside the coverage of Proclamation No. 1716.
• Substantive: The Court held that the issuance of Proclamation No. 164 was an invalid exercise of legislative power. Proclamation No. 1716 was a valid act of legislation issued by President Marcos under Amendment No. 6, and could only be amended by an equally valid act of legislation. Under Article II, Section 1 of the Freedom Constitution, President Aquino exercised legislative power only until a legislature was elected and convened. Because Congress convened on July 26, 1987, President Aquino lost her legislative power on that date. Proclamation No. 164, issued on October 6, 1987, constituted a clear usurpation of legislative power, violating the separation of powers. The Court took exception to its usual practice of not entertaining unraised constitutional questions because the usurpation struck at the most basic constitutional principle.

• Res Judicata — Bars the relitigation of matters finally adjudicated by a competent court. The elements are: (a) the former judgment must be final; (b) the court which rendered it had jurisdiction over the subject matter and the parties; (c) it must be a judgment on the merits; and (d) there must be between the first and second actions identity of parties, subject matter, and cause of action. The Court applied this doctrine to the specific land covered by the first case, emphasizing that only substantial identity of parties is required.
• Separation of Powers — The principle that the executive cannot exercise legislative power vested exclusively in the legislature. The Court applied this principle to nullify Proclamation No. 164, holding that the President's exercise of legislative power under the Freedom Constitution ceased upon the convening of Congress.
• Presumption of Validity of Statutes — The presumption that every statute was duly enacted by the legislature and is therefore valid. The Court held that this presumption cannot apply when there is a clear usurpation of legislative power by the executive branch, as the presumption rests on the premise of valid legislative enactment.

• "Proclamation No. 1716 was issued by the late President Ferdinand E. Marcos on February 17, 1978 in the due exercise of legislative power vested upon him by Amendment No. 6 introduced in 1976. Being a valid act of legislation, said Proclamation may only be amended by an equally valid act of legislation. Proclamation No. 164 is obviously not a valid act of legislation."
• "For this Court to allow such disregard of the most basic of all constitutional principles by reason of the doctrine of presumption of validity of a law would be to turn its back to its sacred duty to uphold and defend the Constitution."

• Mangoma vs. Court of Appeals, 241 SCRA 21 (1995) — Followed for the enumeration of the basic elements of res judicata.
• Suarez vs. Municipality of Naujan, 18 SCRA 682 (1966) — Followed for the rule that only substantial identity, and not absolute identity, of parties is required for res judicata to apply.
• Salas vs. Jarencio, 48 SCRA 734 (1970) and Peralta vs. Comelec, 82 SCRA 30 (1978) — Followed for the presumption of validity of statutes, but distinguished on the ground that the presumption does not apply when there is a clear usurpation of legislative power.

• Article II, Section 1, Proclamation No. 3 (Freedom Constitution) — Provided that the President shall continue to exercise legislative power until a legislature is elected and convened under a new constitution. The Court applied this provision to determine that President Aquino lost her legislative authority when Congress convened on July 26, 1987.
• Amendment No. 6, 1973 Constitution — Vested legislative power in the President. The Court noted this as the basis for the valid exercise of legislative power by President Marcos in issuing Proclamation No. 1716.

Narvasa, C.J., Romero, Francisco, and Panganiban, JJ.