Associate Justice Apolinario D. Bruselas Jr. of the Court of Appeals denied a petition on a property made by the Manila City Government. The said petition is to stop a Manila court from implementing a writ of execution that orders them to pay a lot owner the remaining balance for a private property that has been expropriated in 1997 for public use unless the owner surrenders the duplicate titles of the property.

This decision was ruled in reference to Section 85 of PD 1529 which says that is does not require the private landowner to surrender his certificate of title as a condition to the payment of just compensation.