G.R. No. 175064 - Province of Camarines Sur vs. Court of Appeals

Petitioner: Province of Camarines Sur, represented by Governor Luis Raymund F. Villafuerte, Jr.
Respondents: Court of Appeals; City of Naga, represented by Mayor Jesse M. Robredo.
The property involved is Plaza Rizal, a parcel of land of approximately 4,244 square meters, located within the territorial jurisdiction of the City of Naga, in front of the old provincial capitol building used formerly by Camarines Sur.

Republic Act No. 305 (effective 18 June 1948) converted the Municipality of Naga into the City of Naga.
Republic Act No. 1336 (16 June 1955) transferred the provincial capitol of Camarines Sur from the City of Naga to the barrio of Palestina, Municipality of Pili, which was declared the new provincial capital.

On 13 January 1997, the City of Naga filed a Complaint for Declaratory Relief and/or Quieting of Title against Camarines Sur before the Regional Trial Court (RTC) of Naga City.
The complaint alleged that Camarines Sur claimed ownership and exercised administrative control over Plaza Rizal based on a tax declaration in its name, causing the City of Naga to be excluded from the use and management of the property despite its territorial jurisdiction over it.
The City of Naga did not intend to acquire ownership but sought declaration that administrative control and management of Plaza Rizal be vested in it, relying on Section 2, Article I of RA No. 305, defining the City's territorial jurisdiction.

Camarines Sur filed an Answer with Motion to Dismiss (21 February 1997), asserting:

Legal and absolute ownership over Plaza Rizal.
Section 2, Article I of RA No. 305 only defined territorial jurisdiction, not property ownership or control rights.
No actual controversy existed since Camarines Sur had continuous control of Plaza Rizal, and declaratory relief was inappropriate.
Plaza Rizal was not a public domain property but owned by Camarines Sur and devoted for public use.

The RTC denied the Motion to Dismiss (28 May 1997), finding the issues to raise legal and factual questions for trial.
On 10 March 1999, the RTC ruled for the City of Naga:

Territorial jurisdiction implies administrative control over properties within it.
Sec. 2, Art. I of RA 305 defines territorially where City of Naga exercises control, including Plaza Rizal.
The City Mayor is empowered to control all city property under Sec. 9, Art. II of RA 305.
Administrative control over Plaza Rizal should belong to City of Naga, not Camarines Sur.

Motion for Reconsideration filed by Camarines Sur was denied (Order dated 1 September 1999). The RTC emphasized that the creation of the City ceased Camarines Sur’s administrative control within that territory, and Camarines Sur’s claim of ownership lacked express legislative grant.
Camarines Sur attempted to appeal but notices of appeal were disapproved due to procedural defects and untimeliness.

Camarines Sur filed a Petition for Review on Certiorari under Rule 45 (18 October 1999), docketed as CA-G.R. SP No. 56243, questioning:

The CA denied the petition (Decision dated 28 June 2004), treating the petition as a Rule 65 petition for certiorari and ruling:

Motion for Reconsideration filed by Camarines Sur was denied (Resolution dated 11 August 2006).

Camarines Sur filed the instant Petition for Certiorari under Rule 65, alleging grave abuse of discretion by the CA in dismissing the Petition for Review on Certiorari and treating it as a Petition for Certiorari under Rule 65.
Camarines Sur argued:

The suit for declaratory relief was improper as there was no real controversy.
Administrative control over Plaza Rizal did not automatically transfer to City of Naga upon municipal conversion under RA 305.
The CA erred in applying the law and mischaracterizing the nature of the petition filed.

Whether the Court of Appeals gravely abused its discretion amounting to lack or excess of jurisdiction by treating Camarines Sur’s Petition for Review on Certiorari under Rule 45 as a Petition for Certiorari under Rule 65 and dismissing it on procedural grounds.

Whether the City of Naga properly filed an action for declaratory relief and/or quieting of title regarding the administrative control of Plaza Rizal.

Whether the administrative control and supervision of Plaza Rizal vested in the City of Naga upon its conversion from Municipality to City under RA No. 305, despite Camarines Sur's claim of ownership and prior control.

Nature of Plaza Rizal as property for public use or patrimonial property subject to ownership and control by Camarines Sur.