MANILA, PHILIPPINES – April 21, 2025 – In a landmark decision underscoring the sanctity of private property rights, the Supreme Court of the Philippines has ordered the Department of Education (DepEd) to vacate a parcel of land in Cagayan province, ruling in favor of the registered owner who had been locked in a legal battle with the government.
The High Court’s Second Division, in a decision penned by Senior Associate Justice Marvic M.V.F. Leonen, affirmed the rulings of three lower courts, declaring that Princess Joama Marcosa A. Caleda is the rightful owner and possessor of the contested property, identified as Lot No. 7421 in Solana, Cagayan.
The Core of the Dispute
The case began when Caleda, after purchasing the 10,637-square meter rice land from the heirs of Bueno Gallebo in 2014, discovered that the Solana Fresh Water Fishery School (SFWFS), under DepEd’s supervision, was occupying the property. Despite repeated demand letters, DepEd refused to vacate, claiming it had purchased the land decades prior.
DepEd’s defense shifted during the appeal process. After losing in the trial courts, it argued before the Supreme Court that as a public institution using the land for education, it could not be ejected. The government agency insisted that Caleda’s only recourse was to seek financial compensation, not the return of the property.
Supreme Court’s Decisive Rejection
The Supreme Court soundly rejected DepEd’s arguments, delivering a clear verdict based on several key points:
No Proof of Sale: The Court found that a 1965 Deed of Sale presented by DepEd specifically referred to an adjacent lot, Lot No. 7420, and not the property owned by Caleda. DepEd failed to provide any valid evidence of ownership over Lot No. 7421.
No Acquiescence by Owner: The doctrine protecting government property from ejection requires that the owner must have impliedly consented by failing to act. The Court found that Caleda acted swiftly and diligently, sending demands and filing a case soon after discovering the occupation. Her predecessors could not have consented to something they never agreed to.
Laches Does Not Apply: The Court ruled that the legal principle of laches (loss of rights through unreasonable delay) cannot be used against a registered landowner under the Torrens System, which guarantees the indefeasibility of a title.
No Expropriation Proceedings: Critically, the Court noted that DepEd never initiated formal expropriation proceedings to legally acquire the land for public use. It could not use the court case as a backdoor to eminent domain.
Implications and Final Order
The decision reinforces that government agencies must respect private property rights and follow due process. While the State retains the power of eminent domain, it must be exercised through proper legal channels and with just compensation.
The Supreme Court ordered DepEd, represented by Region II OIC-Regional Director Dr. Estela Carino, to immediately vacate Lot No. 7421 and peacefully turn over its possession to Caleda.
The Court clarified that its ruling does not prevent the government from filing a separate, proper expropriation case to acquire the land in the future, but for now, the right of the private owner prevails.#
