0% found this document useful (0 votes)
214 views1 page

Anti-Graft League of The Philippines v. San Juan: Facts

This case involves a dispute over land that was originally purchased by the Province of Rizal to build a technical college and hospital, but the plans did not materialize. The land was later sold to a private company. The original owner of the land, Ortigas, sued claiming the sale violated the original contract. The land was then repurchased by the Province through a compromise agreement. The petitioner claimed this was an improper use of public funds. However, the court found the petitioner did not have standing to bring the case as a taxpayer suit because there was no showing of unlawful public spending.

Uploaded by

Lloyd Liwag
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
0% found this document useful (0 votes)
214 views1 page

Anti-Graft League of The Philippines v. San Juan: Facts

This case involves a dispute over land that was originally purchased by the Province of Rizal to build a technical college and hospital, but the plans did not materialize. The land was later sold to a private company. The original owner of the land, Ortigas, sued claiming the sale violated the original contract. The land was then repurchased by the Province through a compromise agreement. The petitioner claimed this was an improper use of public funds. However, the court found the petitioner did not have standing to bring the case as a taxpayer suit because there was no showing of unlawful public spending.

Uploaded by

Lloyd Liwag
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 1

Anti-Graft League of the Philippines v.

San Juan
[G.R. No. 97787. August 1, 1996]

FACTS:
On March 20, 1975, President Ferdinand E. Marcos issued Presidential Decree (PD) No. 674,
establishing the Technological Colleges of Rizal and which also directed the Provincial Board of
Rizal (the Board) to provide funds for the purchase of a site and the construction of the necessary
structures thereon. Consequently, the Province of Rizal (Province) bought four parcels of land
located in Ugong Norte, Pasig from Ortigas & Co., Ltd. (Ortigas). However, the projected
construction never materialized because of the decimation of the Province’s resources brought
about by the creation of the Metro Manila Commission (MMC) in 1976.
Twelve years later, with the said property lying idle and the Province needing funds to
propel its 5-year Comprehensive Program, the Board passed Resolution No. 87-205 dated October
15, 1987 authorizing the Governor to sell the property. The said property was eventually sold to
Valley View Realty Development Corporation (Valley View) for a total of P134,523,900.00.
On May 10, 1988, after learning about the sale, Ortigas, filed an action for recission of
contract plus damages with preliminary injunction against the Province (Civil Case No. 55904)
alleging that the latter violated one of the terms of the contract - that the land will be utilized solely
for the construction of the Rizal Technological Colleges and the Rizal Provincial Hospital.
On April 21, 1988, the new provincial officials of the Board adopted Resolution No. 88- 65
which provided for the rescission of the sale between the Province and Valley View on the ground
that the sale was prejudicial to the former. Consequently, Valley View filed Civil Case no. 55913
against the Province for specific performance and damages. However, the said case was dismissed
because the parties executed a compromise agreement.
On March 20, 1989, Civil Case No. 55904 was resolved through execution of a compromise
agreement between the Province and Ortigas. Under the said agreement, the Province agreed to
reconvey the property to Ortigas at a price of P432,398,250.00 payable within two years at an
annual interest rate of 14%. The said amount was higher than the market values separately
determined by Asian Appraisal Inc. and the Provincial Appraisal Committee. Hence, this petition for
certiorari.
ISSUE:
Whether or not the present action is a taxpayer’s suit and that the petitioner has legal
standing to question the transaction entered into by the Board and Ortigas.
HELD:
No. In order to constitute a taxpayer’s suit, two requisites must be met, namely, that public
funds are disbursed by a political subdivision or instrumentality and in doing so, a law is violated or
some irregularity is committed, and that the petitioner is directly affected by the alleged ultra vires
act.
In the said case, the first requirement was not present because the petitioner never referred to such
purchase as an illegal disbursement of public funds but focused on the alleged fraudulent
reconveyance of said property to Ortigas because the price paid was lower than the prevailing
market value of neighboring lots. Since petitioner failed to show that there was unlawful spending
of public money, he, even as a taxpayer, cannot question the transaction validly executed by and
between the Province and Ortigas simply because he is not privy to the contract. Therefore,
petitioner has no locus standi (right to bring an action).

You might also like

pFad - Phonifier reborn

Pfad - The Proxy pFad of © 2024 Garber Painting. All rights reserved.

Note: This service is not intended for secure transactions such as banking, social media, email, or purchasing. Use at your own risk. We assume no liability whatsoever for broken pages.


Alternative Proxies:

Alternative Proxy

pFad Proxy

pFad v3 Proxy

pFad v4 Proxy