G.R. No. 125183 September 29, 1997
Municipality of San Juan, Metro Manila, petitioner, vs. Court of Appeals, Department of Environment and Natural Resources, Corazon de Jesus Homeowners Association, Inc., et al., respondents.

FACTS

On February 17, 1978, President Ferdinand Marcos issued Proclamation No. 1716, reserving certain parcels of public land in San Juan, Metro Manila, for Municipal Government Center Site Purposes. The Municipality of San Juan purchased land in Taytay, Rizal, to resettle squatters occupying the proclaimed area and subsequently began developing its government center by constructing several public buildings. On October 6, 1987, after Congress had convened on July 26, 1987, President Corazon Aquino issued Proclamation No. 164, amending Proclamation No. 1716 by excluding parcels not utilized for government center purposes but actually occupied for residential purposes and declaring them open for disposition under the Public Land Act. On June 1, 1988, respondent Corazon de Jesus Homeowners Association, Inc., filed a petition for prohibition to enjoin municipal officials from demolishing members’ houses, claiming the lots were awarded to them by Proclamation No. 164. The Regional Trial Court dismissed the petition on September 14, 1990, ruling the property was being utilized for government purposes. The Court of Appeals dismissed the appeal on July 17, 1991, and this judgment became final. Disregarding this final judgment, private respondents applied to the DENR for a grant under Proclamation No. 164. To prevent this, the Municipality filed a petition for prohibition against the DENR and the Homeowners Association. The Regional Trial Court enjoined the DENR from disposing of the land, but the Court of Appeals reversed this decision.

ISSUE

The central issue is the correct interpretation and validity of Proclamation No. 164 in relation to Proclamation No. 1716. Specifically, whether the doctrine of res judicata applies due to a prior final judgment and whether Proclamation No. 164 was validly issued.

RULING

The Supreme Court set aside the decision of the Court of Appeals. The Court held that res judicata applies to the portion of land covered by Proclamation No. 164 that was the subject of the earlier final judgment, as there was identity of parties, subject matter, and cause of action. More fundamentally, the Court declared Proclamation No. 164 null and void. Proclamation No. 1716 was a valid legislative act issued under Amendment No. 6 and could only be amended by an equally valid legislative act. President Aquino exercised legislative power under the Freedom Constitution only until Congress convened on July 26, 1987. Since Proclamation No. 164 was issued on October 6, 1987, after Congress had convened, it constituted an invalid exercise of legislative power and a usurpation of congressional authority. Consequently, the DENR was permanently enjoined from enforcing Proclamation No. 164.