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Municipality of La Carlota vs. National Waterworks and Sewerage Authority (NAWASA)

The Supreme Court of the Philippines ruled in favor of the Municipality of La Carlota, stating that the national government cannot take ownership of a municipal waterworks system without just compensation. The case arose when NAWASA assumed control of La Carlota's waterworks system under Republic Act No. 1383, leading the municipality to seek the return of its assets. The ruling emphasizes the need for due process and just compensation when appropriating municipal properties.

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7 views1 page

Municipality of La Carlota vs. National Waterworks and Sewerage Authority (NAWASA)

The Supreme Court of the Philippines ruled in favor of the Municipality of La Carlota, stating that the national government cannot take ownership of a municipal waterworks system without just compensation. The case arose when NAWASA assumed control of La Carlota's waterworks system under Republic Act No. 1383, leading the municipality to seek the return of its assets. The ruling emphasizes the need for due process and just compensation when appropriating municipal properties.

Uploaded by

Maria Carmel Acojedo
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© © All Rights Reserved
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Municipality of La Carlota vs.

National Waterworks and Sewerage


Authority (NAWASA)
G.R. No. L-20232
September 30, 1964

In Municipality of La Carlota vs. National Waterworks and Sewerage Authority


(NAWASA) (G.R. No. L-20232, September 30, 1964), the Supreme Court of the
Philippines addressed the issue of whether the national government could assume
ownership and control of a municipal waterworks system without providing just
compensation.

Facts:
The Municipality of La Carlota owned and operated a waterworks system serving its
residents. With the enactment of Republic Act No. 1383 on June 28, 1955, the
National Waterworks and Sewerage Authority (NAWASA) was established, and the
law mandated the transfer of all municipal waterworks systems to NAWASA.
Pursuant to this law, NAWASA assumed ownership, supervision, administration, and
control of La Carlota's waterworks system, including the collection of water fees
from consumers. In response, the Municipality of La Carlota filed a complaint
seeking the return of ownership, possession, supervision, administration, and
control of its waterworks system.

Issue:
Can the national government, through NAWASA, take ownership and control of a
municipal waterworks system without providing just compensation to the
municipality?

Ruling:
The Supreme Court ruled in favor of the Municipality of La Carlota. The Court held
that the national government cannot appropriate the patrimonial property of
municipal corporations without due process and just compensation. The Court
emphasized that while the government has the power to regulate and supervise
public utilities, it cannot assume ownership of municipal properties without
adhering to constitutional requirements. Consequently, the Court ordered NAWASA
to return the ownership, possession, supervision, administration, and control of the
waterworks system to the Municipality of La Carlota.

Significance:
This decision underscores the principle that municipal corporations have proprietary
rights over their assets, and the national government must provide just
compensation if it seeks to appropriate such properties. The ruling affirms the
constitutional protection against the taking of property without due process and just
compensation, even when the taking is executed by a government entity.

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