The Supreme Court ruled that a law declared unconstitutional is void from its inception, meaning it confers no rights, regardless of reliance on it. This decision underscores that even if individuals believe they are acting lawfully under a statute, its subsequent invalidation negates any claim of right derived from it. This principle affects property rights, contracts, and any legal standing predicated on the unconstitutional law, emphasizing the judiciary’s power to ensure laws conform to constitutional standards.

Squatters’ Rights or Owners’ Might? Unraveling a Land Dispute After Marcos Decree

This case revolves around a property dispute in Caloocan City, stemming from Presidential Decree No. 293 (P.D. 293) issued by President Ferdinand Marcos. The decree invalidated the titles of Carmel Development, Inc. (respondent) over a large property known as Pangarap Village, opening it for disposition to members of the Malacañang Homeowners Association, Inc. (MHAI). Moreto Mirallosa (petitioner), through his predecessor-in-interest, occupied a portion of the land based on this decree. However, the Supreme Court later declared P.D. 293 unconstitutional in the landmark case of Roman Tuason and Remedio V. Tuason, Attorney-in-fact, Trinidad S. Viado v. The Register of Deeds, Caloocan City, Ministry of Justice and the National Treasurer^[14], thus prompting Carmel Development, Inc. to demand that Mirallosa vacate the premises, leading to a legal battle over unlawful detainer and the rights of a builder in good faith.

The central legal question is whether Mirallosa, who occupied the land under the now-defunct P.D. 293, has a right to remain on the property despite the Supreme Court’s declaration of unconstitutionality. The Metropolitan Trial Court (MeTC) initially ruled in favor of Carmel Development, Inc., ordering Mirallosa to vacate. The Regional Trial Court (RTC) reversed this decision, but the Court of Appeals (CA) sided with Carmel Development, Inc., reinstating the MeTC’s order. The Supreme Court was then asked to determine if the MeTC had jurisdiction over the case, whether the Tuason ruling applied to Mirallosa, and if Mirallosa could be considered a builder in good faith.

The Supreme Court affirmed the CA’s decision, holding that the MeTC properly exercised jurisdiction because the case was indeed one of unlawful detainer. An action for unlawful detainer arises when a person unlawfully withholds possession of any land or building after the expiration or termination of the right to hold possession by virtue of any contract, express or implied, according to Samelo v. Manotok Services, Inc., G.R. No. 170509, 27 June 2012, 675 SCRA 132, citing Racaza v. Gozum, 523 Phil. 694, 707 (2006).

In this case, Mirallosa’s possession became unlawful after the Tuason ruling invalidated P.D. 293. The Court emphasized that the one-year prescriptive period for filing an unlawful detainer case begins from the date of the last demand to vacate, which Carmel Development, Inc. complied with. It is not counted from the date that P.D. 293 took effect. The court then cited Heirs of Ampil v. Manahan,^[53], explaining that even if an ownership issue is raised, the determination is only provisional in an unlawful detainer case.

A significant aspect of the ruling is its application of the Tuason decision to Mirallosa, who was not a party to that case. The Supreme Court clarified that a law declared unconstitutional is a nullity and confers no rights on anyone, regardless of their involvement in the original case. The court elucidated this point by quoting Republic v. Court of Appeals^[56]:

The strict view considers a legislative enactment which is declared unconstitutional as being, for all legal intents and purposes, a total nullity, and it is deemed as if had never existed.

This principle ensures that the declaration of unconstitutionality binds not only the parties involved but all persons. The operative fact doctrine, which recognizes interim effects of a law before its invalidation, did not apply here because Mirallosa’s claim was based on an affidavit executed after the Tuason ruling, meaning he was aware of the decree’s unconstitutionality when he occupied the property.

Finally, the Court addressed the issue of whether Mirallosa could be considered a builder in good faith. A builder in good faith is one who believes they have the right to build on the land and is unaware of any defect or flaw in their title, according to Rosales v. Castelltort, 509 Phil. 137, 147 (2005), citing Macasaet v. Macasaet, 482 Phil. 853, 871 (2004) (citation omitted).

However, since Mirallosa occupied the property after the Tuason case, he could not claim ignorance of the law. The Supreme Court explained that judicial decisions form part of the law of the land, and ignorantia legis non excusat, meaning ignorance of the law excuses no one. As such, he loses what he built on the property without the right to indemnity, as stated under Article 449 of the Civil Code^[69].

In summary, the Supreme Court’s decision reinforces the principle that an unconstitutional law has no effect and confers no rights, even if individuals have relied on it in good faith. This ruling has significant implications for property rights and underscores the importance of judicial review in ensuring the constitutionality of laws.

FAQs

What was the key issue in this case?	The key issue was whether Moreto Mirallosa had the right to remain on land he occupied under Presidential Decree No. 293, which was later declared unconstitutional. This involved questions of unlawful detainer, the effect of an unconstitutional law, and whether Mirallosa was a builder in good faith.
What is unlawful detainer?	Unlawful detainer is a legal action to recover possession of property from someone who initially had lawful possession but whose right to possess has expired or terminated. A key element is the demand to vacate and the possessor’s refusal to do so.
What does it mean for a law to be declared unconstitutional?	When a law is declared unconstitutional, it is considered void from its beginning, as if it never existed. It cannot be enforced, and it confers no rights or obligations.
What is the operative fact doctrine?	The operative fact doctrine is an exception to the general rule that an unconstitutional law has no effect. It recognizes the interim effects of a law before it is declared unconstitutional, especially when overturning those effects would create undue hardship.
What is a builder in good faith?	A builder in good faith is someone who builds on land believing they have the right to do so, unaware of any defect or flaw in their title. They may be entitled to reimbursement for improvements made.
Why was Mirallosa not considered a builder in good faith?	Mirallosa was not considered a builder in good faith because he occupied the property after the Supreme Court had already declared P.D. 293 unconstitutional. Thus, he should have been aware of the illegality of his claim.
How does the Tuason case affect those not directly involved?	The Tuason case, which declared P.D. 293 unconstitutional, affects everyone because the declaration of unconstitutionality is binding on all persons. No one can invoke an unconstitutional law or have courts apply it.
What is the significance of the demand letter in this case?	The demand letter is crucial because the one-year period to file an unlawful detainer case starts from the date of the last demand to vacate. This requirement ensures the possessor has a clear notice to leave before legal action is taken.

This case serves as a crucial reminder of the judiciary’s role in safeguarding constitutional principles and ensuring that no one benefits from laws that violate those principles. The decision underscores the importance of due diligence and awareness of legal precedents, especially in matters concerning property rights and land ownership.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: MORETO MIRALLOSA VS. CARMEL DEVELOPMENT, INC., G.R. No. 194538, November 27, 2013