Political Law

Citizens’ Surety and Insurance Co., Inc. vs Judge Ricardo Puno, Register of Deeds Manila

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G.R. No. L-34669 – 119 SCRA 218 – Political Law – Constitutional Law – Equal Protection – Purchase of Land – Barrio Obrero – Equal protection must be invoked by the proper party

In 1956, Resolution No. 542 was passed by the Register of Deeds Manila which provided that only Filipino laborers whose wages do not exceed P180.00/month or P6.00/day and at the same time residents of Manila may be allowed to purchase lands in Barrio Obrero, Tondo, Manila. On 10 October 1966, Maria Barcelon mortgaged her 180 sq. m. land located in Barrio Obrero to Citizens’ Surety and Insurance Co., Inc. (CSICI). CSICI foreclosed the property due to nonpayment and later bought the land. CSICI later sought to register and consolidate the land before the Register of Deeds. The latter denied the application. CSICI the filed a civil suit to have Resolution No. 542 be nullified and for the Register of Deeds to be directed to accept its approve its application. The presiding judge, Ricardo Puno, dismissed the civil suit. CSICI appealed. CSICI averred that Resolution No. 542 is void. It averred: “As may be seen from Sec 4 of Resolution No. 542, only laborers earning not more than P180.00 a month, or P5.00 a day are qualified to buy Lands in Barrio Obrero. Employees working in offices or establishments and earning as much but who are not laborers cannot buy lands in that area. Also persons who are engaged in some calling or occupation earning as much are not also qualified. It should not be overlooked that the intention of the pertinent provisions of the Charter of the City of Manila contained in Sections 97, 98 and 100 of said Charter is to help the poor people of Manila to acquire residential lands on easy terms.” CSICI points out that there is no substantial difference between these laborers to those mentioned in the Resolution.

ISSUE: Whether or not Resolution 542 violates equal protection.

HELD: No. The SC ruled against CSICI. CSICI, which is a corporation and not a lowly paid worker, is not competent to raise this claim. For even if the SC sustain it, no benefit can accrue to CSICI who will nonetheless be disqualified to acquire the lot. Moreover, in the absence of manifest abuse of power, the SC not vent to substitute their judgment for that of the City of Manila which is tasked by its Charter “to acquire private lands in the city and to subdivide the same into home lots for sale on easy terms to residents, giving first priority to the bona-fide tenants or occupants of said lands, and second priority to laborers and low-salaried employees.” Obviously, the questioned resolution merely seeks to implement the Charter provision.

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