CHAPTER VI.

EMINENT DOMAIN

A. Definition and Scope

Where private property is needed for conversion to some public use.
If private property is unwilling to sell his private property, the government can use its coercive
authority.
Also known as the power of expropriation

B. Who May Exercise

Primarily lodged in the national legislature, by delegation, the President, administrative bodies,
local government units, and even private enterprises performing public services.
• Congress
• President of the Philippines
• Various legislative bodies
• Certain public corporations, like National Housing Authority and water districts
• Quasi-public corporations like the Philippine National Railways, PLDT and Meralco.

Requisites for LGUs

• Enactment of ordinance, not a resolution
• Must be for public use, purpose or welfare
• Benefit of the poor and landless

Destruction from Necessity

Destruction from necessity does not come under the right of eminent domain, but under the
right of necessity, of self-preservation.

C. Necessity of Exercise
When the power is exercised by the Legislature, the question of necessity is generally a
political question [Municipality of Meycauayan, Bulacan v. Intermediate Appellate Court, 157
SCRA 640]; but when exercised by a delegate, the determination of whether there is genuine
necessity for the exercise is a justiciable question [Republic v. La Orden de Po. Benedictinos, 1
SCRA 649].

Stages
Determine the validity of expropriation
Payment of just compensation

City of Manila v. Chinese Community of Manila, G.R. No. L-14355, October 25, 1919
FACTS
The City of Manila presented a petition before CFI of said city on December 11, 1916, praying
that certain lands, situated in the distinct of Binondo of said city, construct a public
improvement, namely, the extension of Rizal Avenue, Manila, be expropriated.

In response, the Communidad de Chinos de Manila alleged that no necessity existed for said
appropriation and that the land in question was a cemetery which had been used as such for
many years, and was covered with sepulchers and monuments, and that the same should not
be converted into a street for public purposes. One of the defendants, Ildefonso Tambunting,
offered to grant a right of way for the said extension over other lands, without cost to the
plaintiff, in order that the sepulchers, chapels, and graves of his ancestors may not be disturbed.

The Honorable Simplicio del Rosario deeded that there was no necessity for the expropriation
of the particular strip in question and absolved each of the defendants from all liability under
the complaint, without any finding as to costs. On appeal, the plaintiff contended that the City
of Manila has the authority to expropriate private lands for a public purpose. Section 2429 of
 CHAPTER VI. EMINENT DOMAIN
Act No. 2711 (Charter of the City of Manila) provided that the City of Manila may condemn
private property for public use.

ISSUE
Whether or not the City of Manila can condemn the private property for public use.

RULING
No, while it is true that Section 2429 of Act No. 2711, or the Charter of the City of Manila, may
condemn property for public use, however, the statute does not designate the property to be
taken, nor how it may be taken, the necessity of taking particular property is a question for the
courts. The necessity for conferring the authority upon a municipal corporation to exercise the
right of eminent domain is admittedly within the power of the legislature. But whether the
municipal corporation is exercising the right in a particular case under the conditions imposed
by the general authority is a question which the courts have the right to inquire into.

In the present case, even granting that a necessity exists for the opening of the street in
question, the record contained no proof of the necessity of opening the same through the
cemetery. The record showed that the adjoining and adjacent lands had been offered by the
Tambunting to the city free of charge, answering every purpose of the plaintiff.

Republic v. La Orden de PP Benedictinos de Filipinas G.R. No. L-12792 February 28, 1961
FACTS
On May 27, 1957, the trial court, upon application of the Government, issued an order fixing the
property's provisional value in question at P270,000 and authorizing the appellant to take
immediate possession thereof upon depositing the said amount. The expropriate proceeding
was made to carry out the plan of extending Azcarraga St. (now Recto) to ease and solve the
daily traffic congestion by buying a portion of approximately 6,000 square meter of a bigger
parcel belonging to La Orden.

A motion to dismiss the complaint was filed by La Orden asserting that the property sought to
be expropriated was already dedicated to public use and therefore was not subject for
expropriation, that there was no necessity for the proposed expropriation; that the proposed
Azcaraga Extension could pass through a different site which would entail less expense to the
Government and which would not necessitate the expropriation of a property dedicated to
education. The trial court granted the motion.

ISSUE
Whether or not the expropriation of the property was necessary.

RULING
No, the Supreme Court held that it did not need an extended argument to show whether the
proposed opening of the Azrcarraga extension was necessary to relieve the congestion of traffic
on Legarda Street. It was held to be a question of fact dependent not only upon the facts of
which the trial court very liberally took judicial notice but also upon other factors that do not
appear of record and must, therefore, be established by means of evidence.

In conclusion, the Supreme Court held that the parties should have been given an opportunity
to present their respective evidence upon these factors and others that might be of direct or
indirect help in determining the vital question of fact involved, namely, the need to open the
extension for the above-mentioned purpose.

D. Private Property
Public property – subject to expropriation by national legislature
 CHAPTER VI. EMINENT DOMAIN
Private property – by delegate
Private property already devoted to public use cannot be expropriated by a delegate of
legislature acting under a general grant of authority [City of Manila v. Chinese Community, 40
Phil 349].

All private property capable of ownership may be expropriated, except money and choses in
action. Even services may be subject to eminent domain [Republic v. PLDT, 26 SCRA 620].

Republic v. PLDT, G.R. No. L-18841, January 27, 1969

FACTS
Philippine Long Distance Telephone Company (PLDT) is a public service corporation holding a
legislative franchise under Act 3426, as amended by Commonwealth Act 407, to install,
operate and maintain a telephone system throughout the Philippines and to carry on the
business of electrical transmission of messages within the Philippines and between the
Philippines and the telephone system of other countries.

Soon after its creation, the BOT set up its own government Telephone System (GTS) utilizing
its own appropriation and equipment and by renting the trunk lines of the PLDT to enable
government offices to all private parties. The Bureau has extended its services to the general
public. Through these trunk lines, a GTS subscriber could make a call to a PLDT subscriber in
the same way that the latter could make a call to the former.

BOT entered into an agreement with RCA Communications, Inc. for joint telephone service.
The BOT would convey radio-telephone overseas, all received by RCA to and from local
residents.

PLDT complained that BOT violated conditions since BOT had used the trunk lines for
government offices and even to serve private persons or the general public in competition
with the business of PLDT. PLDT severed the telephone connections of BOT, resulting in the
isolation of the Philippines on telephone services from the rest of the world except the US.

The BOT had proposed that both enter into an interconnecting agreement, with the
government paying for all calls passing through the interconnecting facilities from the GTS to
the PLDT. The PLDT replied that it was willing to enter into an agreement on overseas
telephone service to Europe and Asian countries provided that the BOT would submit to the
jurisdiction and regulations of the Public Service Commission and in consideration of sharing
of gross revenues. Either party did not accept the proposals.

The plaintiff commenced suit against the defendant, praying in its complaint, for judgment
commanding the PLDT to execute a contract with the plaintiff, through the BOT, for the use of
the facilities of defendant’s telephone through the Philippines under such terms and
conditions as the court might consider reasonable, and that a writ of a preliminary injunction
against the defendant company to restrain the severance of the existing telephone
connections and/or restore those severed. The lower court rendered a judgment in favor of
PLDT.

ISSUE
Whether or not the interconnection of Government Telephone System and PLDT can be
subject to expropriation.

RULING
Yes, the Republic of the Philippines, through the Bureau of Telecommunication, may
expropriate interconnections in the exercise of its power of eminent domain and require the
 CHAPTER VI. EMINENT DOMAIN
telephone company to permit interconnection of the Government Telephone System and that
of the PLDT, as the needs of the government service may require, subject to the payment of
just compensation to be determined by the court.

E. Taking
Dispossession of the owner, thus deprived all beneficial use of his property.

Actual Taking
May include trespass without actual eviction of the owner, material impairment of the
value of the property or prevention of the ordinary uses for which the property was
intended

Republic v. Castellvi, G.R. No. L-20620, August 15, 1974

FACTS
On June 26, 1959, the Republic of the Philippines filed a complaint for eminent domain
against Carmen M. Vda. De Castellvi, judicial administratrix of the estate of the late Alfonso
de Castellvi, over a parcel of land in the barrio of San Jose, Foridablanca, Pampanga, and
against Maria Nieves Toledo Gozan over two parcels of land.

The republic alleged that the fair market value of the properties, according to the
Committee on Appraisal for the Province of Pampanga, was not more than P2000 per
hectare, and prayed that the provisional value of the lands be fixed at P259,669.10, that
the court authorized plaintiff to take possession of the lands upon deposit of the amount
with the Provincial treasurer of Pampanga. It was granted.

In her motion to dismiss, Castellvi alleged that the value of the property must be fixed at
P15.00 per square meter, that the republic, through the AFP, had been illegally occupying
her property since July 1, 1956, thereby preventing her from using and disposing of it, thus
causing her damages by way of unrealized profits. However, such property had been
occupied by the Philippine Air Force since 1947 under a contract of lease.

ISSUE
Whether or not the reckoning period of expropriation starts from the year 1947.

RULING
No, the taking of the property of Castellvi must not be reckoned as of the year 1947 when
the Republic first occupied the same pursuant to the contract of lease as it did not deprive
Catellvi of the benefits from such property and that the just compensation to be paid for
the Castellvi property should not be determined on the basis of the value of the property as
of that year.

(memorize this)
Further, the requisites for a valid taking, as laid down by the Supreme Court, are:
a) The expropriator must enter a private property. When by virtue of the lease
agreement, the republic, through the AFP, took possession of the property of Castellvi.
b) The entry must be for more than a momentary period.
c) The entry into the property should be under warrant or color of legal authority. In
this case, it was through a contract of lease;
d) The property must be devoted to public use or otherwise informally appropriated or
injuriously affected; and
e) The utilization of the property for public use must be in such a way as to oust the
owner and deprive him of all beneficial enjoyment of the property. Such circumstance was
not present in this case.
 CHAPTER VI. EMINENT DOMAIN

Hence, the Supreme Court established that just compensation must be computed
from the date of the proceeding.

Constructive Taking

NPC v. Sangkay, G.R. No. 165828, August 24, 2011

FACTS
Pursuant to its legal mandate under Republic Act No. 6395, NPC undertook the Agus River
Hydroelectric Power Plant Project in the 1970s to generate electricity for Mindanao. The
project included constructing several underground tunnels to be used in diverting the
water flow from the Agus River to the hydroelectric plants.

On November 21, 1997, the heirs of Macabangkit Sangkay, as the owners of land situated
in Ditucalan, Iligan City, sued NPC in the RTC for the recovery of damages of the property,
with an alternative prayer for the payment of just compensation. Due to the underground
tunnels, the heirs suffered from the following:

1. The president of the Federation of Arabic Mandans School had rejected their offer
to sell the land because of the danger of the underground tunnel might pose to the
proposed Arabic Language Training Center and Muslims Skills Development Center;
2. Withdrawal by Global Asia Management and Resource Corporation from developing
the land into a housing project for the same reason
3. Refusal of the Al-Amanah Islamic Investment Bank to accept their land as collateral
because of the underground tunnel's presence.

Further, they asserted that the underground tunnel had been constructed without their
knowledge and consent, which deprived them of the agricultural, commercial, industrial,
and residential value of their land, and their land had also become an unsafe place forcing
them and their workers to relocate to safer grounds,

As a counterclaim, Heirs of Macabangkit, stated by the NPC, had no right to compensation

under Section 3(f) of Republic Act No. 6395.

ISSUE
Whether or not the Heirs of Sangkay must be entitled to just compensation.

RULING
Yes, the construction of underground tunnels constituted taking of the land, which entitles
the owners to just compensation. The fixing of just compensation must be based on the
prevailing market value when filing the complaint, instead of reckoning from the time of
taking pursuant to Section 3(h) of Republic Act No. 6395.

Philippine Press Institute v. COMELEC, G.R. No. L-119694 May 22, 1995
FACTS
COMELEC promulgated Resolution No. 2772, directing newspapers to provide free print
space of not less than ½ page for use as "COMELEC space" from March 6, 1995, in the case
of candidates for senator and from March 21, 1995, until May 12, 1995. In the absence of
said newspaper, "COMELEC space" shall be allocated by the Commission, "free of charge,"
among all candidates within the area in which the newspaper, magazine, or periodical was
circulated to enable the candidates to make known their qualifications, their stand on
public issues and their platforms and programs of government. COMELEC Commissioner
sent letters to publishers informing them of the same.
 CHAPTER VI. EMINENT DOMAIN

PPI sought to declare the resolution unconstitutional and void on taking private property
without just compensation. TRO was enforced. The Solicitor General argued that such
resolution and its implementing letter directives were valid as an exercise of the state's
police power.

ISSUE
Whether or not the taking of ½ page for COMELEC constitutes a deprivation of use without
newspaper compensation.

RULING
Yes, to compel print media companies to donate "COMELEC space" amounted to taking of
private personal property for public use. The extent of the taking of deprivation is not
insubstantial measure by the advertising rates ordinarily charged by newspaper publishers,
whether in cities or non-urban areas.

The element of necessity for the taking had not been shown by respondent COMELEC. It
had not been suggested that the PPI members were unwilling to sell print space at their
normal rates to COMELEC for election purposes. It had not been suggested that the
COMELEC had not granted the power of eminent domain either by the Constitution or by
the legislative authority. A reasonable relationship between that power and the
enforcement and administration of election laws by COMELEC must be shown.

Municipality of Daet v. Court of Appeals, G.R. No. L-35861 October 18, 1979
FACTS
Li Seng Gap & Co., Inc. owned a parcel of land situated in Poblacion, Municipality of Daet,
covering an area of 2,717 square meters. Such property was expropriated on August 9,
1962, or 17 years ago where the Municipality of Daet has failed to make the deposit
required to take possession of the property sought to be expropriated.

Hence, this action was filed to fix the fair market value of the property sought to be
expropriated at P200.00 per square meter or for P54,400.00 and the value of improvement
at P36,500.00

ISSUE
Whether or not the valuation was just, fair and reasonable.

RULING
For purposes of just compensation in cases of private property acquired by the government
for use, the basis shall be the current and fair market value as declared by the owner or
administrator or such market value as determined by the assessor, whichever is lower. It is
a cardinal rule of statutory construction that laws shall have prospective effect. The
provisional value of the property, in this case, having already been fixed, the deposit on
February 9, 1973, of the amount of P54,370.00 representing the assessed value of the land
and the deposit on October 27, 1977, of the amount of P25,830.00 representing the
assessed value of the improvement, both pursuant to the said decree, are not sufficient.
Nevertheless, said amounts should be deducted from the total amount due to the private
respondent.

F. Public Use
Expanded Concept
 CHAPTER VI. EMINENT DOMAIN
specifically, urban renewal or redevelopment and the construction of low cost housing is
recognized as a public purpose, not only because of the expanded concept of public use but
also because of specific provisions in the Constitution

Vda. De Ouano v. Republic, G.R. No. 168770, February 9, 2011

FACTS
In 1949, the National Airport Corporation (NAC), MCIAA’s predecessor agency, pursued a
program to expand the Lahug Airport in Cebu City. As an assurance from the government,
there is a promise of reconveyance or repurchase of the said property so long as Lahug
ceases its operation or transfer its operation to Mactan-Cebu Airport. Some owners
refused to sell, and that the Civil Aeronautics Administration filed a complaint about the
expropriation of said properties for the expansion of the Lahug Airport. The trial court
declared said properties to be used upon expanding said projects and order for just
compensation to the landowners. It directed the latter to transfer a certificate of
ownership in the name of the plaintiff.

At the end of 1991, Lahug Airport completely ceased its operation while the Mactan-Cebu
airport opened to accommodate incoming and outgoing commercial flights. This then
prompted the landowners to demand the reconveyance of said properties being
expropriated by the trial court under the power of eminent domain. Hence, these two
consolidated cases arise.

ISSUE
Whether or not the MCIAA can reconvey the lands to petitioners.

RULING
Yes, through expropriation proceedings, the notion that the government acquires
unrestricted ownership over or a fee simple title to the covered land is no longer
untenable. Expropriated lands should be differentiated from a piece of land, ownership of
which was transferred by way of an unconditional purchase and sale contract freely
entered by two parties, one without obligation to buy and other without the duty to sell.
In that case, the free simple concept really comes into play. There is really no occasion to
apply the “fee simple concept” if the transfer is conditional.

The taking of private land in expropriation proceedings is always conditioned on its

continued devotion to its public purpose. Once the purpose is terminated or preempt only
abandoned, then the former owner, if he so desires, may see its reversion subject, of course
to the return at the very least of the just compensation received

Manosca v. Court of Appeals, G.R. No. 106440, January 29, 1996

FACTS
Petitioners Alejandro, Asuncion, and Leonica Manosca inherited a piece of land located at
P. Burgos St., Calzada, Taguig, Metro Manila, with an area of about 492 square meters.
When the parcel was ascertained by the National Historical Institute (NHI) to have been
the birth site of Felix Y. Manalo, the founder of Iglesia ni Cristo, it passed Resolution No. 1,
series of 1986, pursuant to Section 4 of Presidential Decree No. 260, declaring the land to
be a national historic landmark. It was approved by the Minister of Education, Culture and
Sports. The Secretary of Justice opined on the legality of the measure and said in part that
the birth site of the founder of the Iglesia ni Cristo, the late Felix Y. Manalo, who,
admittedly, had made contributions to Philippine history and culture which has been
declared as the national landmark.
 CHAPTER VI. EMINENT DOMAIN
ISSUE
Whether or not the expropriation was for public use.

RULING
Yes, the purpose of setting up the marker is essential to recognize the distractive
contribution of the late Felix Manalo to the culture of the Philippines rather than to
commemorate his founding and leadership of the Iglesia ni Cristo. Hence, the petition was
denied.

Traditional Concept
As a requirement for eminent domain, “public use” is the general concept of meeting public
need or public exigency. It is not confined to actual use by the public in its traditional sense.
The idea that “public use” is strictly limited to clear cases of “use by the public” has been
abandoned. The term “public use” has now been held to be synonymous with “public
interest”, “public benefit”, “public welfare”, and “public convenience”

Heirs of Ardona v. Reyes, G.R. No. L-60549, October 26, 1983

FACTS
Presidential Decree No. 564, the Revised Charter of the Philippine Tourism Authority, and
Proclamation No. 2052 declared the barangay of Sibugay, Malubog, Babag, and Sirao,
including the proposed Lusaran Dam in the city of Cebu and the municipalities of Argao
and Dalaguete in the province of Cebu as tourist zones.

The Philippine Tourism Authority filed four complaints with CFI-Cebu City to expropriate
some 282 hectares of rolling land situated in barangays Malubog and Babag, Cebu city,
under PTA’s expressed authority to acquire by purchase, by negotiation, or by
condemnation proceedings any private land within and without tourist zones. It was
intended to develop integrated resort complexes of selected and well-defined geographic
areas with potential tourism value. An electric power grid will also be established by NPC,
as well as a deep well and drainage system. Complimentary support facilities (malls,
coffee shops, etc.) will also be created.

The defendants alleged that the taking was allegedly not impressed with public use under
the Constitution. Further, they argued that, assuming PTA has such power, the intended
use cannot be paramount to the determination of a land reform area; that limiting the
amount of compensation by legislative fiat is constitutionally repugnant; and that since
the land is under the land reform program, it is the court of Agrarian Reforms which has
jurisdiction over the case.

ISSUE
Whether or not the public use requirement had been complied with.

RULING
Yes, the concept of public use is not limited to traditional purposes for constructing roads,
bridges, and the like. The idea that “public use” means “use by the public” has been
discarded. As long as the purpose of the taking is public, then the power of eminent
domain comes into play. It is accurate to state that whatever may be beneficially
employed for the general welfare satisfies the requirement of public use. The petitioners
have not shown that the area is a developed island reform area and that the affected
persons have been given emancipation patents and land transfer certificates. The contract
clause has never been regarded as a barrier to the exercise of police power and, likewise,
eminent domain.
 CHAPTER VI. EMINENT DOMAIN

G. Just Compensation
The full and fair equivalent of the property taken; it is the fair market value of the property. It
is settled that the market value of the property is “that sum of money which a person,
desirous but not compelled to buy, and an owner, willing but not compelled to sell, would
agree on as a price to be given and received therefor”.

National Housing Authority v. Reyes, G.R. No. L-49439 June 29, 1983
FACTS
National Housing Authority (NHA) filed a complaint with the then Court of Agrarian Relations
against Quirino and Luciano Austria to expropriate the parcel of land owned by Quirino
Austria needed to expand Dasmarninas Resettlement Project. It was able to secure an order
placing it in possession. Thereafter, Quirino Austria filed a motion to withdraw a deposit in the
amount of P6,600.00. This sum was equivalent to the value of the property assessed for
taxation purposes and deposited pursuant to PD No. 42. However, it was disputed by the
petitioner on the ground that the owner's declaration of P1,400.00, the amount lower than
the assessor's assessment, was the proper valuation. Thus, Austria cannot withdraw more
than P1,400.00.

ISSUE
Whether or not the property's valuation must be based on PD 76 as amended by PD No. 464
regarding the valuation of the property.

RULING
Since the valuation under the statute was expressly provided, and such a statute was not
questioned, the valuation must be in accordance with such law. It is repeating a commonplace
to state that the court has no choice except to yield to its command on a matter where the
applicable law speaks in no uncertain language. The case was remanded to the lower court for
further action.

Export Processing Zone Authority v. Dulay, G.R. No. L-59603, April 29, 1987
FACTS
On January 15, 1879, the President of the Philippines issued Proclamation No. 1811, reserving
a certain parcel of land of public domain situated in the City of Lapu-Lapu, Island of Mactan,
Cebu for the establishment of an export processing zone by EPZA. The proclamation included,
among others, four (4) parcels of land owned and registered under the name of San Antonio
Development Corporation.

EPZA offered to purchase the parcels of land with the valuation set forth in Section 92, PD No.
464, as amended. The parties failed to reach an agreement regarding the sale of the property.
Hence, it filed with the then CFI-Cebu a complaint about expropriation with a prayer for the
issuance of a writ of possession. Such writ of possession authorized the petitioner to take
immediate possession of the premises.

ISSUE
Whether or not Section 5 to 8, Rule 67 of the Revised Rules of Court had been repealed or
deemed amended by PD No. 1583 insofar as the appointment of commissions to determine
the just compensation is concerned.

RULING
No, the decrees constituted impermissible encroachment on judicial prerogatives. Without
such decree, the courts still have the power and authority to determine just compensation,
 CHAPTER VI. EMINENT DOMAIN
independent of what was state by the decree and to this effect, to appoint commissioners for
such purpose.

H. Power of Inferior Domain

Refer to Camarines sur vs. CA.
Memorize: Ordinance vs. resolution.
Municipality of Parañaque v. VM Realty Corp., G.R. No. 127820, July 20, 1998
FACTS
Pursuant to Sangguniang Bayan Resolution No. 93-95, Series of 1993, the Municipality of
Paranaque filed on September 20, 1993, a complaint about the expropriation of two parcels
of land, located at Paranaque, Manila, owned by V.M. Realty Corporation. The complaint was
filed to alleviate the living conditions of the underprivileged by providing homes for the
homeless. It was also stated that an offer to enter into a negotiated sale of the property with
the private respondent, which the latter did not accept.

ISSUE
Whether or not the expropriation was valid.

RULING
No, under Section 19 of RA 7160, before an LGU can exercise the power of eminent domain,
the following requisites must be met:

a.) An ordinance is enacted by the local legislative council authorizing the local chief
executive, on behalf of the LGU, to exercise the power of eminent domain or pursue
expropriation proceedings over a particular private property.

b.) the power of eminent domain is exercised for public use, purpose, or for the benefit of the
poor and the needy;

c.) there is a payment of just compensation as required by the Constitution and other
pertinent laws; and

d.) A valid and definite offer has been previously made to the owner of the property sought to
be expropriated, but said the offer was not accepted.

In the case at bar, the first requisite was not met since the local chief executive sought to
exercise eminent domain pursuant to a resolution, not the municipal council's ordinance.
Hence, the petition was denied.

Cases:
1. City of Manila v. Chinese Community of Manila, G.R. No. L-14355, October 25, 1919
2. Republic v. La Orden de PP Benedictinos de Filipinas G.R. No. L-12792 February 28, 1961
3. Republic v. PLDT, G.R. No. L-18841, January 27, 1969
4. Republic v. Castellvi, G.R. No. L-20620, August 15, 1974 - Essential elements of taking - memorize
5. NPC v. Sangkay, G.R. No. 165828, August 24, 2011
6. Philippine Press Institute v. COMELEC, G.R. No. L-119694 May 22, 1995
7. Municipality of Daet v. Court of Appeals, G.R. No. L-35861 October 18, 1979
8. Vda. De Ouano v. Republic, G.R. No. 168770, February 9, 2011
9. Manosca v. Court of Appeals, G.R. No. 106440, January 29, 1996
10. Heirs of Ardona v. Reyes, G.R. No. L-60549, October 26, 1983
11. National Housing Authority v. Reyes, G.R. No. L-49439 June 29, 1983
12. Export Processing Zone Authority v. Dulay, G.R. No. L-59603, April 29, 1987
 CHAPTER VI. EMINENT DOMAIN
13. Municipality of Parañaque v. VM Realty Corp., G.R. No. 127820, July 20, 1998 -power of inferior
domain - memorize