Rabuco vs Villegas 55 SCRA 656

Facts

The constitutionality of RA No. 3120 was assailed by the city officials of the City of Manila contending that the conversion of the lots in Malate area into disposable and alienable lands of the state and placing its administration and disposal to the LTA to be subdivided into lots and selling it to bona fide occupants thereof in installments constitutes a deprivation of the City of Manila of its property by providing for its sale without the payment of just compensation.

Issue

Whether or not the properties in dispute may be disposed without paying just compensation to the City of Manila?

Held

The court held that the assailed RA 3120 is constitutional. The lots in question are owned by the City of Manila in its public and governmental capacity and are therefore public property over which Congress has absolute control as distinguished from patrimonial property owned by it which cannot be deprived from the City without just compensation and without due process. RA 3120 expressly provides that the properties are reserved for the purpose of communal property and ordered its conversion into disposable and alienable lands of the state to be sold to its bona fide occupants. It has been an established doctrine that the state reserves its rights to classify its property under its legislative prerogative and the court cannot interfere on such power of the state.