Title
Republic vs. Lardizabal
Case
G.R. No. L-41351
Decision Date
Oct 28, 1977
The Republic of the Philippines challenged Baguio City's 25-year renewable leases of a sanitary reservation, arguing they violated Executive Proclamation No. 312 and constituted unauthorized acts of dominion. The Supreme Court nullified the leases, ruling they exceeded administrative authority and endangered public health.
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Case Digest (G.R. No. L-41351)

Facts:

  1. Background of the Case:
    The Republic of the Philippines filed a petition against the City of Baguio, its Mayor (Luis L. Lardizabal), Councilors, and private respondents (Times Transportation Co., Inc., Dacanay Express, Inc., and Anastacio Imson) challenging the validity of leases executed over portions of the Baguio Sanitation Camp and Slaughterhouse Reservation.

  2. Executive Proclamation No. 312:
    Issued on April 23, 1930, this proclamation reserved the Slaughterhouse Compound in Baguio City as a sanitary camp and livestock yard under the administration of the City of Baguio. It expressly prohibited the sale or colonization of the reserved area.

  3. City Council Resolutions and Leases:

    • Resolution No. 12-70 (January 7, 1970): Authorized the lease of 9,195 square meters to Times Transportation Co., Inc. for 25 years, renewable for another 25 years. This was later amended to reduce the area to 5,982 square meters.
    • Resolution No. 355-71 (July 8, 1971): Authorized the lease of 3,214 square meters to Anastacio Imson for 25 years, renewable for another 25 years.
    • Resolution No. 535-71 (September 8, 1971): Authorized the lease of 2,411 square meters to Dacanay Express, Inc. for 25 years, renewable for another 25 years.
  4. Objections to the Leases:
    The City Health Officer and City Legal Officer of Baguio objected to the leases, arguing that they endangered public health and safety and were acts of dominion beyond the authority of the City Council.

  5. Petitioner’s Claims:
    The Republic of the Philippines sought to nullify the resolutions and leases, arguing that they violated Executive Proclamation No. 312 and constituted acts of dominion rather than administration.

Issue:

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Ruling:

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Ratio:

  1. Leases as Acts of Dominion:
    The Court held that a lease for 25 years, renewable for another 25 years, is not a mere act of administration but an act of dominion. Such long-term leases effectively deprive the government of the use of the reserved land for its intended purpose (sanitary camp and livestock yard).

  2. Violation of Executive Proclamation No. 312:
    The leases violated the terms of Executive Proclamation No. 312, which prohibited the disposition of the reserved area. The City of Baguio, as an administrator, had no authority to execute leases that were inconsistent with the proclamation’s purpose.

  3. Lack of Authority:
    The City Council lacked the authority to perform acts of dominion over the reserved land. The leases were deemed invalid because they exceeded the administrative powers granted to the City of Baguio under the proclamation.

  4. Public Interest and Health:
    The Court emphasized that the leases endangered public health and safety by deviating from the intended use of the reservation as a sanitary camp and livestock yard.


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