Case Doctrines: Police Power, Eminent Domain and Taxation

Ichong vs. Hernandez

The treaty is always subject to qualification or amendment by a subsequent law, and the same may never curtail or restrict the scope of the police power of the State.

Lutz vs. Araneta

The tax levied by the challenged statute is for a regulatory purpose, namely, to provide ways and means for the rehabilitation and stabilization of the sugar industry. x x x The law is thus primarily an exercise of the police power of the state and taxation was merely used to implement the state’s power.

Department of Education vs. San Diego

The State has the responsibility to harness its human resources and to see to it that they are not dissipated or, no less worse, not used at all.

Republic of the Philippines vs. La Orden de  PP. Benedictinos de Filipinas

Whether or not the purpose of the taking is necessary is a question of fact dependent only upon the facts of which the trial court very liberally took judicial notice but also other facts that do not appear of record and must, therefore, be established by means of evidence.

City of Manila vs. Chinese Community

Whether or not the municipal corporation or entity 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.

Republic of the Philippines vs. PLDT

Normally, the power of eminent domain results in taking or appropriation of title to, and possession of, the expropriated party; but no cogent reason appears why said power may not be availed of to impose only a burden upon the owner of the condemned property, without loss of title and possession. x x x the state may, in the interest of national welfare, transfer utilities to public ownership upon payment of just compensation, there is no reason why a state may not require a public utility to render services in the general interest, provided just compensation is paid therefor.

National Housing Authority vs. Reyes

Although in an expropriation proceeding the court technically would still have the power to determine the just compensation for the property, following the applicable decrees, its task would be relegated to simply stating the lower value of the property as declared either by the owner or the assessor.

It is violative of due process to deny the owner the opportunity to prove that the valuation in the tax documents is unfair or wrong.  And it is repulsive to the basic concepts of justice and fairness to allow the haphazard work of a minor bureaucrat or clerk to absolutely prevail over the judgement of a court promulgated only after expert commissioners have actually viewed the property, after evidence and arguments pro and con have been presented, and after all factors and considerations essential to a fair and just determination have been judiciously evaluated.

Association of Small Land Owners vs. Secretary of Agrarian Reform

It cannot be denied from these cases that the traditional medium for the payment of just compensation is money and no other. x x x This is not an ordinary expropriation where only a specific property of relatively limited area is sought to be taken by the State from its owner for a specific and perhaps local purpose.  what we deal here is a revolutionary kind of expropriation. x x x Considering the vast areas of land subject to expropriation under the laws before us, we estimate that hundreds of billions of pesos will be needed, far more indeed than the amount of P50 billion initially appropriated, which is already staggering as it is by our present standards.  Such amount is in fact not even fully available in cash at this time. x x x

Republic vs. Lim

In cases where the government failed to pay the compensation within five years from the finality of the judgement in the expropriation proceedings, the owner concerned shall have the right to recover possession of their property.  This is in connection with the principle that ‘the government cannot keep the property and dishonour the judgement.’

Lladoc vs. Commissioner of Internal Revenue

The exemption in Sec. 22(3) of Article VI of the Constitution is only from the payment of taxes assessed on such properties enumerated as property taxes as distinguished from excise taxes. x x x Manifestly, a gift tax is not within the exemption provisions.

Yu Cong Eng vs. Trinidad

It would be oppressive and arbitrary to prohibit all Chinese merchants from maintaining a set of books in the Chinese language, and in the Chinese characters and thus prevent them from keeping advised of the status of their business and directing conduct.