VILLANUEVA v. CASTAÑEDA, JR.
FACTS
Petitioners are owners of stalls in a talipapa located in a land owned by the municipal government. They were ed to lease the said land through a municipal council resolution in 1961.
The municipal government demolished the the stalls and subsequently issued a new resolution revoking the right previously granted to the vendor. Said resolution indicated that the said area will be a parking space for the town plaza.
Petitioners brought an action against the municipal government alleging that they have the right to use the said lang because the resolution allowing them to use the area constitutes a contract between them (vendors) and the municipal government.
CFI dismissed the petition and ordered the petitioners to be evicted from the area. But such eviction was not enforced and the number of stall owners even grew.
After a few years, the municipal again resolved to demolish the stalls
ISSUE:
1. Whether or not the resolution in 1961 conferred contractual rights to the stall owners making them lawful lessees of the land
2. Whether or not the said area are dedicated for public use
HELD:
1. There was no dispute that the land occupied by the petitioners was previously used as a town plaza and being such it is considered as beyond the commerce of man and cannot be the subject of lease or any contractual undertaking. The petitioners had no right in the first place to occupy the disputed premises.
2. The proliferation of the stalls caused several repercussions to the area such as
> the makeshift and flammable materials has made the area susceptible of fire endangering public safety
> said stalls have obstructed the way going to the real public market
> the filthy conditions of the stalls has aggravated health and sanitation problems
> the area has contributed to the obstruction of the flow of traffic
3. Assuming that there was a valid contract (and that the land is not for public use), the petitioners must yield to the police power exercised by the municipal government. It is a well settled rule that any valid contract may be cancelled if it causes danger to the public.
