Delfin Spouses owned a 28,800 square meter parcel of land in Townsite, Suarez, Iligan City. Sometime in 1982, respondent National Housing Authority (NHA) forcibly took possession of a 10,798 square meter portion of the property. Despite their repeated demands for compensation, the NHA failed to pay the value of the property. The Delfin Spouses thus, filed their Complaint for "Payment of Parcel(s) of Land and Improvements and Damages".
In a letter to the Director of Lands in 1987, it was indicated that the Iligan Property was already occupied by June 1945 and that it had already released for agricultural purposes in favor of its occupants. Before Deputy Public Land Inspector recommended the issuance of a patent in favor of petitioner, upon investigation in the premises of the land, it was found and ascertained that the land was first entered, occupied and possessed and cultivated by him since the year June 1945 up to the present.
NHA alleged that the Delfin Spouses' property was part of a military reservation area. It cited Proclamation No. 2143 as having supposedly reserved the area in which property is situated for Iligan City's slum improvement and resettlement program, and the relocation of families who were dislocated by the National Steel Corporation's five-year expansion program.
Regional Trial Court (RTC) declared the NHA in default, rendering a Decision in favor of the Delfin Spouses. On NHA’s appeal, the Court of Appeals reversed the RTC’s Decision:
The Court of Appeals ruled that the characterization of the property is no longer an issue because the NHA already conceded that the property is disposable public land by citing Proclamation No. 2143, which characterized the property as "a certain disposable parcel of public land." However, the Delfin Spouses supposedly failed to establish their possession of the property since June 12, 1945, as required in Section 48(b) of the Public Land Act.
Q: Are petitioners entitled to just compensation for the Iligan City property occupied by respondent National Housing Authority?\
Yes, petitioners are entitled to just compensation for the Iligan City property occupied by respondent National Housing Authority.
The right to be justly compensated whenever private property is taken for public use cannot be disputed. Article III, Section 9 of the 1987 Constitution states that Section 9. Private property shall not be taken for public use without just compensation. While petitioners may not claim title by prescription, they may, nevertheless, claim title pursuant to Section 48 (b) of Commonwealth Act No. 141 (the Public Land Act).
Section 48 enabled the confirmation of claims and issuance of titles in favor of citizens occupying or claiming to own lands of the public domain or an interest therein. Section 48 (b) specifically pertained to those who "have been in open, continuous, exclusive, and notorious possession and, occupation of agricultural lands of the public domain, under a bona fide claim of acquisition or ownership, since June 12, 1945":
Section 48(b) of the Public Land Act therefore requires that two (2) requisites be satisfied before claims of title to public domain lands may be confirmed: first, that the land subject of the claim is agricultural land; and second, open, continuous, notorious, and exclusive possession of the land since June 12, 1945.
In this case, petitioners acquired title over the Iligan Property pursuant to Section 48(b) of the Public Land Act. First, there is no issue that the Iligan Property had already been declared to be alienable and disposable land. Second, Deputy Public Land Inspector’s letters to the Director of Land nevertheless attest to a previous finding that the property had already been occupied as early as June 1945.
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