ABELLANA V. CA
208 SCRA 316
Manglapus was the grantee of a free patent. In the free patent issued to him, there was a provision granting the government reservation for public easements and servitudes. After he was given the patent, the NIA entered
into his premises and started constructing canals.
Where the land was originally public land, and awarded by free patent with a reservation for a legal easement of a right of way in favor of the government, just compensation need not be paid for the taking of the part thereof for public use as an easement of right of way.