Title
City of Naga vs. Court of Appeals
Case
G.R. No. L-37289
Decision Date
Apr 12, 1989
Dispute over sale of public land by Camarines Sur to Naga City; sales voided due to lack of presidential approval, indemnity granted for improvements.
dispute
conveyance
vacate premises
A

Case Digest (G.R. No. L-37289)

Facts:

  • Background and Election Context
    • In the November 1959 general elections of Camarines Sur, Provincial Governor Juan Trivino (Nacionalista) was defeated by Apolonio G. Maleniza (Liberal), who subsequently assumed office with a new Provincial Board.
    • Prior to leaving office, the outgoing administration passed Resolution No. 1103 authorizing Governor Trivino to execute a deed of sale without consideration in favor of the City of Naga for two parcels of land with improvements, originally belonging to the Province.
  • Execution of Conveyances
    • On November 23, 1959, Governor Trivino executed two deeds of sale:
      • One deed (Exhibit G) conveyed a parcel of 80,000 square meters where the Camarines Sur High School complex was erected (including classroom buildings, library, grandstand, etc.).
      • A second deed (Exhibit G-1) conveyed a 19,044-square-meter parcel devoted to horticulture, farming, gardening, and the study of poultry and pig-raising.
    • The sales consideration for both conveyances was nominally set at one peso (P1.00), which was never actually paid.
  • Possession, Use, and Improvements
    • On November 25, 1959, the City of Naga moved its offices to the athletes’ quarters (a newly constructed building) and to the ground floor of the new grandstand within the High School Complex.
    • The city housed its police, fire departments, and assessment division in these buildings.
    • To suit its office purposes, the City of Naga spent P14,901.14 to improve the athletes’ quarters and the grandstand’s ground floor.
  • Initiation of the Lawsuit
    • On December 9, 1959, Apolonio G. Maleniza, in his capacity as taxpayer and governor-elect of Camarines Sur, filed a complaint:
      • Seeking annulment of the conveyances (deeds of sale) that transferred the land from the Province to the City.
      • Claiming that the properties, being dedicated to public use, were not valid subject matter for private contracts or donations without proper procedure.
      • Requesting damages through specified monthly rentals and a writ of preliminary injunction to restrain the transfer of administrative control of the properties.
    • The complaint was accompanied by copies of public documents purporting to evidence the sale by Governor Trivino based on a resolution of the Provincial Board.
    • The defendant Provincial Board argued:
      • The complaint failed to state a cause of action.
      • The plaintiff lacked the necessary legal personality and capacity to sue.
      • The sales were subject to Presidential approval and, thus, the action was premature.
    • The motion to dismiss by the provincial board was denied, and the board was ordered to file an answer.
  • Developments in the Proceedings
    • In January 1960, following the change in leadership, the newly elected Provincial Board revoked the earlier Resolution No. 1103 by passing Resolution No. 42, S. of 1960.
    • The old Provincial Board, having ceased to exist, was declared in default for not filing an answer to the complaint.
    • The City of Naga filed its answer, maintaining:
      • Its lack of direct knowledge regarding the complaint’s material averments.
      • Affirmative and special defenses regarding the plaintiff’s capacity and the requirement of Presidential approval for the conveyances.
    • A counterclaim for damages against the plaintiff was also raised by the City.
    • A writ of preliminary injunction was issued, restricting the City’s occupation of part of the properties and preventing the transfer of administrative control of the Camarines Sur High School.
  • Intervention and Related Issues
    • The Republic of the Philippines intervened on the ground that:
      • One of the parcels conveyed included the site of the Camarines Sur Trade School, which had been converted into the National School of Arts and Trades pursuant to R.A. No. 825.
      • The Province was required to transfer the school site and associated buildings to the National Government.
    • Upon negotiation, the City of Naga waived its rights over the portion occupied by the school, solidifying the intervention matter.
  • Trial and Lower Court Decision
    • The trial was conducted with notable appearances:
      • Assistant Provincial Fiscal Jose Nepomuceno appeared for the plaintiff amidst controversy regarding his representation, given previous inconsistent positions of the Provincial Fiscal Office.
      • The court allowed his appearance despite discrepancies in the pleadings regarding the plaintiff’s capacity (the complaint stated him as governor-elect rather than the incumbent Governor).
    • The lower court (Court of First Instance of Camarines Sur) rendered a decision on June 27, 1962, which:
      • Declared Resolution No. 1103 and the corresponding deeds of sale (Exhibits G and G-1) null and void.
      • Ordered the City of Naga to vacate the properties.
      • Awarded damages to the Province at P600.00 per month for the use of the improved facilities.
      • Made the writ of preliminary injunction permanent.
      • Imposed the costs on the defendant, the City of Naga.
  • Appeal and Issues Raised
    • The City of Naga timely appealed the decision to the Court of Appeals (CA-G.R. No. 32440), which on July 30, 1973, affirmed the lower court’s ruling.
    • On further review, the petition raised the following assigned errors:
      • The nullification of the two conveyances of land in favor of the City.
      • The awarding of damages against the City of Naga for improvements made.

Issues:

  • Whether the conveyances (deeds of sale) executed by the outgoing Provincial Governor were valid despite being done without the required Presidential approval as mandated by Section 2068 of the Revised Administrative Code.
  • Whether the awarding of damages to the City of Naga for the improvements made on the athletes’ quarters and the grandstand ground floor was proper and fair under the circumstances.
  • Whether any error was committed by the Court of Appeals in its affirmation of the trial court decision concerning both the nullification of the conveyances and the damages awarded against the City.
  • The procedural issues and representational controversies arising from the plaintiff’s capacity (governor-elect versus incumbent governor) and the effect of such discrepancies on the merits of the case.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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