Primary Holding

The Court held that the judicial declaration of the unconstitutionality of a law should apply retroactively to cases that were still pending at the time of the declaration.

Background

This case involved the expropriation of land for a highway project where the government wanted to use a method of compensation that had been declared unconstitutional in a previous case.

Facts

• 1. The Republic sought to expropriate land for a highway.
• 2. The private respondents argued for compensation based on fair market value, not the lower value set by a decree.
• 3. The decree's valuation method had been previously declared unconstitutional.

Arguments of the Petitioners

• 1. The Republic argued that the declaration of unconstitutionality should not be applied retroactively to this case, as it was not assailed before the lower court.

Arguments of the Respondents

• 1. The private respondents argued that they were entitled to just compensation based on the fair market value of the property, as the method used by the Republic had been declared unconstitutional.

Issues

• 1. The main issue was whether the judicial declaration of the unconstitutionality of a law should be applied retroactively to a pending case where the constitutionality of the law was not challenged in the lower court.

Ruling

• 1. The Supreme Court held that the unconstitutionality of a law should be applied retroactively to pending cases.

Doctrines

• 1. Doctrine of Operative Fact: Recognizes that a judicial declaration of invalidity does not always nullify past actions based on the invalidated law.
• 2. Principle of Legal Certainty: Ensures consistency in the application of laws.

Key Excerpts

• 1. "An unconstitutional act is not a law; it confers no right; it imposes no duties; it affords no protection; it creates no office; it is, in legal contemplation, inoperative, as if it had not been passed."
• 2. "The strict view considers a legislative enactment which is declared unconstitutional as being, for all legal intents and purposes, a total nullity, and it is deemed as if it had never existed."

Precedents Cited

• 1. Export Processing Zone Authority (EPZA) vs. Dulay: This case declared the questioned decree unconstitutional.
• 2. Norton v. Shelby: Supported the view that an unconstitutional act is not a law and has no effect.

Statutory and Constitutional Provisions

• 1. Article 7 of the Civil Code of the Philippines: Deals with the effect of the unconstitutionality of a law.
• 2. Rule 67 of the Revised Rules of Court, as amended: Concerns the procedure for expropriation cases, including the requirement for a preliminary deposit.