Facts: Respondent National Housing Authority (NHA) filed complaints for the expropriation of sugarcane lands belonging to the petitioners. The stated public purpose of the expropriation was the expansion of the Dasmariñas Resettlement Project to accommodate the squatters who were relocated from the Metropolitan Manila area. The trial court rendered judgment ordering the expropriation of these lots and the payment of just compensation. The Supreme Court affirmed the judgment of the lower court.
A few years later, petitioners contended that respondent NHA violated the stated public purpose for the expansion of the Dasmariñas Resettlement Project when it failed to relocate the squatters from the Metro Manila area, as borne out by the ocular inspection conducted by the trial court which showed that most of the expropriated properties remain unoccupied. Petitioners likewise question 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. Hence, it is claimed that respondent NHA has forfeited its rights and interests by virtue of the expropriation judgment and the expropriated properties should now be returned to herein petitioners.
Issue: Whether or not the judgment of expropriation was forfeited in the light of the failure of respondent NHA to use the expropriated property for the intended purpose but for a totally different purpose.
Held: The Supreme Court held in favor of the respondent NHA. Accordingly, petitioners cannot insist on a restrictive view of the eminent domain provision of the Constitution by contending that the contract for low cost housing is a deviation from the stated public use. It is now settled doctrine that the concept of public use is no longer limited to traditional purposes. The term "public use" has now been held to be synonymous with "public interest," "public benefit," "public welfare," and "public convenience." Thus, whatever may be beneficially employed for the general welfare satisfies the requirement of public use."
In addition, 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. Moreover, the Constitution itself allows the State to undertake, for the common good and in cooperation with the private sector, a continuing program of urban land reform and housing which will make at affordable cost decent housing and basic services to underprivileged and homeless citizens in urban centers and resettlement areas. The expropriation of private property for the purpose of socialized housing for the marginalized sector is in furtherance of social justice.
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