G.R. No. 49 - Municipality of Antipolo vs. Community of Cainta

Pablo de la Cruz, representing the community of Cainta, petitioned for the return of 92 quinones of common lands.
The petition stated that these lands, originally granted as commons to the ancestors of Cainta’s inhabitants, had been leased long ago to the people of Antipolo.
The lease was imposed in return for the payment of one real per balita, amounting to 115 pesos per annum.

Under the original organization of the town of Cainta, the lands were allocated to its inhabitants and later forfeited due to rebellion.
After pardon and subsequent submission, the common lands were restored to the township with a stipulation that they could never be conveyed or encumbered.
At an unspecified period, these lands were leased to Antipolo, and the ground rent was initially paid to the township and later to the government of Morong.
In 1887, the general government exempted the common lands of Cainta from the payment of any canon to the government, leading Antipolo to cease payment while continuing to enjoy the lands.

The governor of Morong, as part of the hearing ordered by the central office, issued an interrogatory to both townships.

To Antipolo: They claimed no written contract existed and asserted they considered the lands as ancestral property received.
To Cainta: They also admitted the absence of a written contract, explained that the township had received rent payments for many years, and contended that the lands were inherently its property.

A consulting attorney was called upon for an opinion; he acknowledged the uncertainty regarding the lease terms and the absence of any supporting documents.
The bureau investigating the matter opined that, owing to the lack of evidence on the purported lease and the established beneficial title of Cainta, the lands should revert to Cainta under the conditions prescribed by Article 1577 of the Civil Code.
This opinion was corroborated by the director-general of the civil administration and confirmed by the Governor-General of the Islands on February 28, 1896.

Following the administrative resolution, a contentious administrative complaint was filed by the municipality of Antipolo on August 3, 1896.
The government attorney filed an answer on April 22, 1898, with the community of Cainta later joining proceedings.
Evidence was presented by both parties, and it was noted that:

Cainta had consistently demanded only the return of the enjoyment of the lands.
The government's executive order aimed at reuniting the dominium utile with the dominium directum, thereby effecting plenum dominium over the lands.
The cause of action was initially premised on a contract of lease, whose object was clearly limited to the enjoyment or use of the lands, not the full title.
The lack of evidence regarding the existence or terms of the lease raised questions on the proper remedy and the locus of jurisdiction.

It was observed that the administrative resolution and subsequent proceedings dealt with a dispute over property rights—a subject traditionally reserved for the ordinary courts.
The contention arose regarding whether the administrative authorities, within the ambit of their jurisdiction (particularly under the law of November 23, 1888, and relevant provisions of article 4, paragraph 2), had the power to adjudicate on matters affecting civil property rights.
Previous decisions indicated that administrative courts had jurisdiction only over contracts involving public service or similar administrative functions and not on private or civil property disputes.
An earlier petition by Pablo de la Cruz in 1891, which sought a grant of common lands, had been decisively resolved, emphasizing that disputes over such contracts should fall under the ordinary courts.

Whether the administrative bodies had the power to declare the termination of the lease and order the return of the beneficial title of the 92 quinones of common lands to the town of Cainta.
Whether administrative resolution was proper when the subject matter involved a dispute over civil property rights rather than a public service contract.

The absence of a written contract or explicit evidence regarding the lease terms and duration.
Whether the longstanding practice of Antipolo in enjoying the lands and paying a ground rent sufficed to establish any legally binding contractual obligation.

Whether the remedy deployed—i.e., the reconversion from usufruct (or analogous rights) to plenum dominium—appropriately addressed the nature of the alleged lease contract.
Whether the administrative ordering of the return of lands, when a mere contractual right of enjoyment was contested, went beyond its jurisdiction.

Whether the action in effect constituted a revindicatory action impacting property rights that should be exclusively under the purview of the ordinary courts.
How prior administrative decisions and customary practices influence the interpretation and enforcement of such ancient contractual arrangements.