POLICE

POWER

ICHONG VS. HERNANDEZ

protection and expedient for its promotion. If objectives and methods are alike constitutionally valid, no reason is
seen why the state may not levy taxes to raise funds for their prosecution and attainment. Taxation may be made
with the implement of the states police power. In addition, it is only rational that the taxes be obtained from those
that will directly benefit from it. Therefore, the tax levied under the Sugar Adjustment Act is held to be constitutional.

[101 PHIL 1155; L-7995; 31 MAY 1957]

ASSO. OF SMALL LANDOWNERS VS. SEC. OF DAR
FACTS: Republic Act 1180 or commonly known as An Act to Regulate the Retail Business was passed. The said law
provides for a prohibition against foreigners as well as corporations owned by foreigners from engaging from retail
trade in our country. This was protested by the petitioner in this case. According to him, the said law violates the
international and treaty of the Philippines therefore it is unconstitutional. Specifically, the Treaty of Amity between
the Philippines and China was violated according to him.
Issue:

[175 SCRA 343; G.R. NO. L-78742; 14 JUL 1989]

Several petitions are the root of the case:
a. A petition alleging the constitutionality of PD No. 27, EO 228 and 229 and RA 6657. Subjects of the petition are a 9-
hectare and 5 hectare Riceland worked by four tenants. Tenants were declared full owners by EO 228 as qualified
farmers under PD 27. The petitioners now contend that President Aquino usurped the legislatures power.

Whether or Not Republic Act 1180 is a valid exercise of police power.

Held:
According to the Court, RA 1180 is a valid exercise of police power. It was also then provided that police power can
not be bargained away through the medium of a treaty or a contract. The Court also provided that RA 1180 was
enacted to remedy a real and actual danger to national economy posed by alien dominance and control. If ever the
law infringes upon the said treaty, the latter is always subject to qualification or amendment by a subsequent law and
the same may never curtain or restrict the scope of the police power of the state.
LUTZ VS. ARANETA
[98 Phil 148; G.R. No. L-7859; 22 Dec 1955]
FACTS: Walter Lutz, as the Judicial Administrator of the Intestate Estate of Antonio Jayme Ledesma, seeks to recover
from J. Antonio Araneta, the Collector of Internal Revenue, the sum of money paid by the estate as taxes, pursuant to
the Sugar Adjustment Act. Under Section 3 of said Act, taxes are levied on the owners or persons in control of the
lands devoted to the cultivation of sugar cane. Furthermore, Section 6 states all the collections made under said Act
shall be for aid and support of the sugar industry exclusively. Lutz contends that such purpose is not a matter of public
concern hence making the tax levied for that cause unconstitutional and void. The Court of First Instance dismissed
his petition, thus this appeal before the Supreme Court.

b. A petition by landowners and sugarplanters in Victorias Mill Negros Occidental against Proclamation 131 and EO
229. Proclamation 131 is the creation of Agrarian Reform Fund with initial fund of P50Billion.
c. A petition by owners of land which was placed by the DAR under the coverage of Operation Land Transfer.
d. A petition invoking the right of retention under PD 27 to owners of rice and corn lands not exceeding seven
hectares.
Issue:
Whether or Not the aforementioned EOs, PD, and RA were constitutional.
Held:
The promulgation of PD 27 by President Marcos was valid in exercise of Police power and eminent domain.
The power of President Aquino to promulgate Proc. 131 and EO 228 and 229 was authorized under Sec. 6 of the
Transitory Provisions of the 1987 Constitution. Therefore it is a valid exercise of Police Power and Eminent Domain.

Whether or Not the tax levied under the Sugar Adjustment Act ( Commonwealth Act 567) is unconstitutional.

RA 6657 is likewise valid. The carrying out of the regulation under CARP becomes necessary to deprive owners of
whatever lands they may own in excess of the maximum area allowed, there is definitely a taking under the power of
eminent domain for which payment of just compensation is imperative. The taking contemplated is not a mere
limitation of the use of the land. What is required is the surrender of the title and the physical possession of said
excess and all beneficial rights accruing to the owner in favour of the farmer.

Held:

A statute may be sustained under the police power only if there is concurrence of the lawful subject and the method.

The tax levied under the Sugar Adjustment Act is constitutional. The tax under said Act is levied with a regulatory
purpose, to provide means for the rehabilitation and stabilization of the threatened sugar industry. Since sugar
production is one of the great industries of our nation, its promotion, protection, and advancement, therefore
redounds greatly to the general welfare. Hence, said objectives of the Act is a public concern and is therefore
constitutional. It follows that the Legislature may determine within reasonable bounds what is necessary for its

Subject and purpose of the Agrarian Reform Law is valid, however what is to be determined is the method employed
to achieve it.

Issue:

TIO VS. VIDEOGRAM REGULATORY BOARD

[151 SCRA 208; G.R. No. L-75697; 18 Jun 1987]

The case is a petition filed by petitioner on behalf of videogram operators adversely affected by Presidential Decree
No. 1987, An Act Creating the Videogram Regulatory Board" with broad powers to regulate and supervise the
videogram industry.
A month after the promulgation of the said Presidential Decree, the amended the National Internal Revenue Code
provided that:

We find no clear violation of the Constitution which would justify us in pronouncing Presidential Decree No. 1987 as
unconstitutional and void. While the underlying objective of the DECREE is to protect the moribund movie industry,
there is no question that public welfare is at bottom of its enactment, considering "the unfair competition posed by
rampant film piracy; the erosion of the moral fiber of the viewing public brought about by the availability of
unclassified and unreviewed video tapes containing pornographic films and films with brutally violent sequences; and
losses in government revenues due to the drop in theatrical attendance, not to mention the fact that the activities of
video establishments are virtually untaxed since mere payment of Mayor's permit and municipal license fees are
required to engage in business."

"SEC. 134. Video Tapes. There shall be collected on each processed video-tape cassette, ready for playback,
regardless of length, an annual tax of five pesos; Provided, That locally manufactured or imported blank video tapes
shall be subject to sales tax."

LOZANO VS. MARTINEZ

"Section10. Tax on Sale, Lease or Disposition of Videograms. Notwithstanding any provision of law to the contrary,
the province shall collect a tax of thirty percent (30%) of the purchase price or rental rate, as the case may be, for
every sale, lease or disposition of a videogram containing a reproduction of any motion picture or audiovisual
program.

FACTS: A motion to quash the charge against the petitioners for violation of the BP 22 was made, contending that no
offense was committed, as the statute is unconstitutional. Such motion was denied by the RTC. The petitioners thus
elevate the case to the Supreme Court for relief. The Solicitor General, commented that it was premature for the
accused to elevate to the Supreme Court the orders denying their motions to quash. However, the Supreme Court
finds it justifiable to intervene for the review of lower court's denial of a motion to quash.

Fifty percent (50%) of the proceeds of the tax collected shall accrue to the province, and the other fifty percent
(50%) shall accrue to the municipality where the tax is collected; PROVIDED, That in Metropolitan Manila, the tax shall
be shared equally by the City/Municipality and the Metropolitan Manila Commission.
The rationale behind the tax provision is to curb the proliferation and unregulated circulation of videograms including,
among others, videotapes, discs, cassettes or any technical improvement or variation thereof, have greatly prejudiced
the operations of movie houses and theaters. Such unregulated circulation have caused a sharp decline in theatrical
attendance by at least forty percent (40%) and a tremendous drop in the collection of sales, contractor's specific,
amusement and other taxes, thereby resulting in substantial losses estimated at P450 Million annually in government
revenues.
Videogram(s) establishments collectively earn around P600 Million per annum from rentals, sales and disposition of
videograms, and these earnings have not been subjected to tax, thereby depriving the Government of approximately
P180 Million in taxes each year.

[146 SCRA 323; G.R. No. L-63419; 18 Dec 1986]

Issue: Whether or not BP 22 is constitutional as it is a proper exercise of police power of the State.
Held: The enactment of BP 22 a valid exercise of the police power and is not repugnant to the constitutional inhibition
against imprisonment for debt.
The offense punished by BP 22 is the act of making and issuing a worthless check or a check that is dishonored upon
its presentation for payment. It is not the non-payment of an obligation which the law punishes. The law is not
intended or designed to coerce a debtor to pay his debt.
The law punishes the act not as an offense against property, but an offense against public order. The thrust of the law
is to prohibit, under pain of penal sanctions, the making of worthless checks and putting them in circulation. An act
may not be considered by society as inherently wrong, hence, not malum in se but because of the harm that it inflicts
on the community, it can be outlawed and criminally punished as malum prohibitum. The state can do this in the
exercise of its police power.

The unregulated activities of videogram establishments have also affected the viability of the movie industry.
CITY GOVERNMENT OF QUEZON CITY VS. ERICTA
Issue:
[122 SCRA 759; G.R. No. L-34915; 24 Jun 1983]
Whether or not tax imposed by the DECREE is a valid exercise of police power. Whether or nor the DECREE is
constitutional .
Held:

Section 9 of Ordinance No. 6118, S-64, entitled "Ordinance Regulating The Establishment, Maintenance And
Operation Of Private Memorial Type Cemetery Or Burial Ground Within The Jurisdiction Of Quezon City And Providing
Penalties For The Violation Thereof" provides:

Taxation has been made the implement of the state's police power. The levy of the 30% tax is for a public purpose. It
was imposed primarily to answer the need for regulating the video industry, particularly because of the rampant film
piracy, the flagrant violation of intellectual property rights, and the proliferation of pornographic video tapes. And
while it was also an objective of the DECREE to protect the movie industry, the tax remains a valid imposition.

Sec. 9. At least six (6) percent of the total area of the memorial park cemetery shall be set aside for charity burial of
deceased persons who are paupers and have been residents of Quezon City for at least 5 years prior to their death, to
be determined by competent City Authorities. The area so designated shall immediately be developed and should be
open for operation not later than six months from the date of approval of the application.
For several years, the aforequoted section of the Ordinance was not enforced but seven years after the enactment of

the ordinance, the Quezon City Council passed a resolution to request the City Engineer, Quezon City, to stop any
further selling and/or transaction of memorial park lots in Quezon City where the owners thereof have failed to
donate the required 6% space intended for paupers burial.

EMINENT DOMAIN

The Quezon City Engineer then notified respondent Himlayang Pilipino, Inc. in writing that Section 9 of the ordinance
would be enforced.

[40 Phil 349; No. 14355; 31 Oct 1919]

Respondent Himlayang Pilipino reacted by filing a petition for declaratory relief, prohibition and mandamus with
preliminary injunction seeking to annul Section 9 of the Ordinance in question. Respondent alleged that the same is
contrary to the Constitution, the Quezon City Charter, the Local Autonomy Act, and the Revised Administrative Code.
Issue:
Whether or Not Section 9 of the ordinance in question is a valid exercise of police power.
Held:
Section 9 of the City ordinance in question is not a valid exercise of police power. Section 9 cannot be justified under
the power granted to Quezon City to tax, fix the license fee, and regulate such other business, trades, and occupation
as may be established or practiced in the City.
Bill of rights states that 'no person shall be deprived of life, liberty or property without due process of law' (Art. Ill,
Section 1 subparagraph 1, Constitution). On the other hand, there are three inherent powers of government by which
the state interferes with the property rights, namely-. (1) police power, (2) eminent domain, (3) taxation.
The police power of Quezon City is defined in sub-section 00, Sec. 12, Rep. Act 537 that reads as follows:
To make such further ordinance and regulations not repugnant to law as may be necessary to carry into effect and
discharge the powers and duties conferred by this act and such as it shall deem necessary and proper to provide for
the health and safety, ..., and for the protection of property therein; and enforce obedience thereto with such lawful
fines or penalties as the City Council may prescribe under the provisions of subsection (jj) of this section.

CITY OF MANILA VS. CHINESE COMMUNITY

Facts: The City of Manila, plaintiff herein, prayed for the expropriation of a portion private cemetery for the
conversion into an extension of Rizal Avenue. Plaintiff claims that it is necessary that such public improvement be
made in the said portion of the private cemetery and that the said lands are within their jurisdiction.
Defendants herein answered that the said expropriation was not necessary because other routes were available. They
further claimed that the expropriation of the cemetery would create irreparable loss and injury to them and to all
those persons owing and interested in the graves and monuments that would have to be destroyed.
The lower court ruled that the said public improvement was not necessary on the particular-strip of land in question.
Plaintiff herein assailed that they have the right to exercise the power of eminent domain and that the courts have no
right to inquire and determine the necessity of the expropriation. Thus, the same filed an appeal.
Issue:
Whether or not the courts may inquire into, and hear proof of the necessity of the expropriation.
Held:
The courts have the power of restricting the exercise of eminent domain to the actual reasonable necessities of the
case and for the purposes designated by the law. The moment the municipal corporation or entity attempts to
exercise the authority conferred, it must comply with the conditions accompanying the authority. The necessity for
conferring the authority upon a municipal corporation to exercise the right of eminent domain is admittedly within
the power of the legislature. But 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 that the courts have the right to
inquire to.

The power to regulate does not include the power to prohibit. The power to regulate does not include the power to
confiscate. The ordinance in question not only confiscates but also prohibits the operation of a memorial park
cemetery, because under Section 13 of said ordinance, 'Violation of the provision thereof is punishable with a fine
and/or imprisonment and that upon conviction thereof the permit to operate and maintain a private cemetery shall
be revoked or cancelled. The confiscatory clause and the penal provision in effect deter one from operating a
memorial park cemetery.

PERCIVAL MODAY vs COURT OF APPEALS

Moreover, police power is defined by Freund as 'the power of promoting the public welfare by restraining and
regulating the use of liberty and property'. It is usually exerted in order to merely regulate the use and enjoyment of
property of the owner. If he is deprived of his property outright, it is not taken for public use but rather to destroy in
order to promote the general welfare.

Authorizing the Municipal Mayor to Initiate the Petition for Expropriation of a One (1) Hectare Portion of Lot No.
6138-Pls-4 Along the National Highway Owned by Percival Moday for the Site of Bunawan Farmers Center and Other
Government Sports Facilities.

It seems to the court that Section 9 of Ordinance No. 6118, Series of 1964 of Quezon City is not a mere police
regulation but an outright confiscation. It deprives a person of his private property without due process of law, nay,
even without compensation.

In due time, Resolution No. 43-89 was approved by then Municipal Mayor Anuncio C. Bustillo and transmitted to the
Sangguniang Panlalawigan for its approval. Sangguniang Panlalawigan disapproved said Resolution and returned it
with the comment that expropriation is unnecessary considering that there are still available lots in Bunawan for the
establishment of the government center.

FACTS:
On July 23, 1989, the Sangguniang Bayan of the Municipality of Bunawan in Agusan del Sur passed Resolution No. 43-
89,

The Municipality of Bunawan, herein public respondent, subsequently filed a Petition for Eminent Domain against
petitioner Percival Moday before the RTC. Public respondent municipality filed a Motion to Take or Enter Upon the
Possession of Subject Matter of This Case stating that it had already deposited with the municipal treasurer the
necessary amount in accordance with Section 2, Rule 67 of the Revised Rules of Court and that it would be in the
governments best interest for public respondent to be allowed to take possession of the property. The Regional Trial
Court granted respondent municipalitys motion to take possession of the land. That the Sangguniang Panlalawigans
failure to declare the resolution invalid leaves it effective. that the duty of the Sangguniang Panlalawigan is merely to
review the ordinances and resolutions passed by the Sangguniang Bayan under the old LGC. that the exercise of
eminent domain is not one of the two acts enumerated in Section 19 thereof requiring the approval of the
Sangguniang Panlalawigan. CA upheld the trial court. Meanwhile, the Municipality of Bunawan had erected three
buildings on the subject property.
ISSUE: whether a municipality may expropriate private property by virtue of a municipal resolution which was
disapproved by the Sangguniang Panlalawigan.
HELD: YES.
Eminent domain, the power which the Municipality of Bunawan exercised in the instant case, is a fundamental State
power that is inseparable from sovereignty. It is governments right to appropriate, in the nature of a compulsory sale
to the State, private property for public use or purpose. Inherently possessed by the national legislature the power of
eminent domain may be validly delegated to local governments, other public entities and public utilities. For the
taking of private property by the government to be valid, the taking must be for public use and there must be just
compensation
The Municipality of Bunawans power to exercise the right of eminent domain is not disputed as it is expressly
provided for in Batas Pambansa Blg. 337, the Local Government Code 18 in force at the time expropriation
proceedings were initiated. Section 9 of said law states:
Section 9.Eminent Domain. A local government unit may, through its head and acting pursuant to a resolution of
its sanggunian, exercise the right of eminent domain and institute condemnation proceedings for public use or
purpose.
POLITICAL LAW; LOCAL GOVERNMENT CODE (B.P. 337); POWER OF THE SANGGUNIANG PANLALAWIGAN TO REVIEW
ORDINANCES, RESOLUTIONS AND EXECUTIVE ORDERS PROMULGATED BY THE MUNICIPAL MAYOR; DECLARATION OF
INVALIDITY MUST BE ON THE SOLE GROUND THAT IT IS BEYOND THE POWER OF THE SANGGUNIAN BAYAN OR
MAYOR TO ISSUE THE RESOLUTION, ORDINANCE OR ORDER UNDER REVIEW.
REPUBLIC VS. CASTELVI
[58 SCRA 336; G.R. No. L-20620; 15 Aug 1974]
In 1947, the republic, through the Armed Forces of the Philippines (AFP), entered into a lease agreement with Castelvi
on a year-to-year basis. When Castelvi gave notice to terminate the lease in 1956, the AFP refused. She then
instituted an ejectment proceeding against the AFP. In 1959, however, the republic commenced the expropriation
proceedings for the land in question.
Issue:

Whether or Not the compensation should be determined as of 1947 or 1959.

Held:
The Supreme Court ruled that the taking should not be reckoned as of 1947, and that just compensation should
not be determined on the basis of the value of the property as of that year.
The requisites for taking are: 1) the expropriator must enter a private property, 2) the entry must be for more than a
momentary period, 3) it must be under warrant or color of authorities, 4) the property must be devoted for public use
or otherwise informally appropriated or injuriously affected, and 5) the utilization of the property for public use must
be such a way as to oust the owner and deprive him of beneficial enjoyment of the property. Under Sec. 4 Rule 67 of
the Rules of Court, just compensation is to be determined as of the date of the filing of the complaint. The
Supreme Court has ruled that when the taking of the property sought to be expropriated coincides with the
commencement of the expropriation proceedings, or takes place subsequent to the filing of the complaint for
eminent domain, the just compensation should be determined as of the date of the filing of the complaint. In the
instant case, it is undisputed that the Republic was placed in possession of the Castelvi property, by authority of
court, on August 10, 1959. The taking of the Castelvi property for the purposes of determining the just
compensation to be paid must, therefore, be reckoned as of June 26, 1959 when the complaint for eminent domain
was filed. There is no basis to the contention of the Republic that a lease on a year-to-year basis can give rise to
permanent right to occupy since by express provision a lease made for a determinate time, as was the lease of
Castelvi land in the instant case, ceases upon the day fixed, without need of a demand (Art. 1669, New Civil Code).
The Supreme Court, however, did not apply Art. 1250 of the New Civil Code for the adjustment of the peso rate in
times of extraordinary inflation or deflation because in eminent domain cases the obligation to pay arises from law
independent of contract.
National Power Corporation v Judge Jocson 206 SCRA 520 (1992)
expropriation case amt. for just compensation in dispute judge held in abeyance the write of possession order
due to petitioner while increasing outright provisional value of land without hearing.

Facts: The petitioner files a special civil action for certiorari to annul the order issued by respondent judge in violation
of deprivation of the right of the petitioner for due process. The petitioner filed 7 eminent domain cases in the
acquisition of right of way easement over 7 parcels of land in relation to the necessity of building towers and
transmission line for the common good with the offer of corresponding compensation to landowners affected with
the expropriation process. However, both parties did not come to an agreement on just compensation thereby
prompting petitioner to bring the eminent domain case. Respondent judge found existing paramount public interest
for the expropriation and thereby issued an order determining the provisional market value of the subject areas
based on tax declaration of the properties. The petitioner, in compliance to the order of respondent judge, deposited
corresponding amount of the assessed value of said lands in the amount of P23,180,828.00 with the Philippine
National Bank. Respondents land owners filed motion for reconsideration asserting that the assessed value is way too
low and that just compensation due them is estimated as P29,970,000.00. Immediately the following day, respondent
judge increased the provisional value to that stated in the motion for reconsideration and ordered petitioner to
deposit the differential amount within 24 hours from receipt of order while holding in abeyance the writ of
possession order pending compliance to said order which the petitioner immediately complied. Thereafter,
respondent judge ordered petitioner to pay in full amount the defendants for their expropriated property. Petitioner
assailed such order to be in violation of due process and abuse of discretion on the part of the respondent judge

hence this petition.

Issue: Whether or not the respondent judge acted in grave abuse of discretion and whether or not the petitioner was
deprived of due process of law.
Held: The court ruled that PD No. 42 provides that upon filing in court complaints on eminent domain proceeding and
after due notice to the defendants, plaintiff will have the right to take possession of the real property upon deposit of
the amount of the assessed value with PNB to be held by the bank subject to orders and final disposition of the court.
The respondent judge failed to observe this procedure by failure to issue the writ of possession to the petitioner
despite its effort to deposit the amount in compliance to the mandate of law. Furthermore, the respondent judge
erred in increasing the provisional value of properties without holding any hearing for both parties. The instant
petition was granted by the court setting aside the temporary restraining order and directing respondent judge to
cease and desist from enforcing his orders.
There are 2 stages in the action of expropriation:

On July 12, 1999, Atty. Baltazar and Engr. Cruz submitted their report, recommending as payment for just
compensation P800.00 per sq m for the residential lot and P700.00 per sq m for the agricultural lot. On October 28,
1999, the RTC rendered judgment, declaring as well-grounded, fair and reasonable the compensation for the property
as recommended by Atty.Baltazar and Engr. Cruz.
ISSUE: Whether or not the just compensation was achieved with regards to the fair market value of the residential
and agricultural property?
HELD:
The trial court fixed the just compensation for the property as follows: (1) P499.00 per sq mon the 17,195 sq m
agricultural portion of the subject land; and (2) P800.00 per sq m on the6,565 sq m residential portion of the lot.
Noticeably, the trial court did not blindly accept the recommendation of majority of the commissioners of P800.00
per sq m for the residential lot and P700.00 per sq m for the agricultural lot. Indeed, the trial court took into account
the evidence of the parties, in tandem with the findings and recommendation of the majority of the commissioners.
Considering that such valuation of the trial court as affirmed by the CA is reasonable as it is and supported by the
evidence on record, we find no compelling reason to disturb the same.

2. Eminent domain action is concerned with the determination by the Court of the "just compensation for the
property sought to be taken." This is done by the Court with the assistance of not more than three (3) commissioners
whose findings are deemed to be final.

The constant loud buzzing and exploding sounds emanating from the towers and transmission lines, especially on
rainy days; the constant fear on the part of the landowners that the large transmission lines looming not far above
their land and the huge tower in front of their lot will affect their safety and health; and the slim chance that no one
would be interested to buy the remaining portions on each side of the residential lot affected by the project, to the
damage of the landowners, both as to future actual use of the land and financial gains to be derived therefrom,
makes the instant case fall within the ambit of expropriation.

G.R. No. 170945, September 26, 2006NATIONAL POWER CORPORATION vs. MARIA MENDOZA SAN PEDRO

1. Determination of the authority of the plaintiff to exercise the power of eminent domain and the propriety of its
exercise in the context of the facts involved in the suit.

FACTS:
The National Power Corporation (NPC) is a government-owned-and-controlled corporation created to undertake the
development of hydro-electric generation of power and the production of electricity from any and all sources; and
particularly the construction, operation, and maintenance of power plants, auxiliary plants, dams, reservoirs, pipes,
mains, transmission lines, power stations and substations, and other works for the purpose of developing hydraulic
power from any river, lake, creek, spring and waterfalls in the Philippines and supplying such power to the inhabitants
thereof. Under Republic Act No.6395, as amended, the NPC is authorized to enter private property provided that the
owners thereof shall be indemnified for any actual damage caused thereby.
For the construction of its San Manuel-San Jose 500 KV Transmission Line and Tower No.SMJ-389, NPC negotiated
with Maria Mendoza San Pedro, then represented by her son, Vicente, for an easement of right of way over her
property, Lot No. 2076. The property, which was partly agricultural and partly residential land, was located in
Barangay Partida, Norzagaray, Bulacan and covered by Tax Declaration No. 00386. On June 19, 1997, Maria executed
a Right of Way Grant in favor of NPC over the lot for P1,277,886.90. The NPC paid her P524,635.50 for the damaged
improvements thereon.
The payment voucher for the residential portion of the lot valued at P6,000,000.00 (atP600.00 per square meter) was
then processed. However, the NPC Board of Directors approved Board Resolution No. 97-246 stating that it would pay
only P230.00 per sq m for the residential portion and P89.00 per sq m for the agricultural portion.