Reyes v NHA

FACTS:
For the purpose of the expansion of the Dasmarias Resettlement Project to accommodate the
squatters who were relocated from the Metropolitan Manila area, NHA filed expropriation
complaints on Reyes sugarcane lots. The expropriation court directed NHA to pay adjudicated
compensation for the expropriated properties; while Reyes must pay the corresponding capital
gains tax on the subject properties. Later Reyes alleged that NHA had not relocated squatters
from the Metropolitan Manila area on the expropriated lands (in violation of the stated public
purpose for expropriation) and had not paid the just compensation fixed by the court; and that
these justify the forfeiture of NHAs rights and interests over the expropriated lots. But NHA
justifies the delay to pay just compensation by reason of the failure of petitioners to pay the
capital gains tax and to surrender the owners duplicate certificates of title. Reyes questions the
public nature of the use by respondent NHA when it entered into a contract for the construction
of low cost housing units, which is allegedly different from the stated public purpose in the
expropriation proceedings.

ISSUE: Whether or not NHA satisfies the requirement of public use

HELD:
Yes, since at present whatever may be beneficially employed for the general welfare satisfies
the requirement of public use. Moreover, jurisprudence has it that the expropriation of private
land for slum clearance and urban development is for a public purpose even if the developed area
is later sold to private homeowners, commercials firms, entertainment and service companies,
and other private concerns. When land has been acquired for public use, the former owner retains
no rights in the land, and the public use may be abandoned, or the land may be devoted to a
different use, without any impairment of the estate or title acquired, or any reversion to the
former owner.
In modifying the appealed decision, the Court ordered NHA to pay just compensation with
interest, emphasizing that, although the court finds NHAs nonpayment to be unfounded and
unjustified, plaintiffs are not entitled to recover possession of their expropriated lots, but only to
demand the market value of the same, since the lots are still devoted to the public use for which
they were expropriated.