Salas vs Jarencio (1972)

petitioners-appellants: RAFAEL S. SALAS, in his capacity as Executive

Secretary; CONRADO F. ESTRELLA, in his capacity as Governor of the Land
Authority; and LORENZO GELLA, in his capacity as Register of Deeds of
Manila
respondents-appellees: HON. HILARION U. JARENCIO, as Presiding Judge of
Branch XXIII, Court of First Instance of Manila; ANTONIO J. VILLEGAS, in his
capacity as Mayor of the City of Manila; and the CITY OF MANILA
PONENTE: Justice ESGUERRA
G.R. No. L-29788
August 30, 1972
TOPICS:
FACTS:
CFI rendered a decision declaring the City of Manila the owner of a
parcel of land occupied by squatters.
The City requested the President to convert the property into a Patrimonial
property of the City. The request to convert such land into patrimonial
property was acted upon and later on it was converted as such under R.A No.
4118.
The land was set for sale by the City to various occupants.
The TCT was turned over to Land Authority pursuant to the said law. The City
filed an injunction case contending that the R.A. 4118 is unconstitutional as it
violates the right of the city over the parcel of land without due process and
just compensation.
ISSUE: WON the land in question is patrimonial property of the City.
RULING: No.
The property in question is only held in trust for the State for the benefit of
its inhabitants, whether it is for governmental or proprietary purposes.

ISSUE: WON the City was deprived of its right over the land without due
process and just compensation.
RULING: No.
The City of Manila was not deprived of anything it owns, either under the due
process clause or under the eminent domain provisions of the Constitution. If
it failed to get from the Congress the concession it sought of having the land
involved given to it as its patrimonial property, the Courts possess no power
to grant that relief. Republic Act No. 4118 does not, therefore, suffer from
any constitutional infirmity.
Opinion:
I agree with the ruling. It appears that the City only wants to convert the said
land into patrimonial property in order to gain profits out of it in its private
capacity.