G.R. No. 155051 - Rural Bank of Anda, Inc. vs. Roman Catholic Archbishop of Lingayen-Dagupan

The property in dispute is Cadastral Lot 736, situated in the Poblacion of Binmaley, Pangasinan.
Lot 736 has an approximate area of 1,300 square meters and is a component of a larger subdivision known as Lot 3.
Lot 3 includes adjacent properties – Cadastral Lot 737 (known as Imelda’s Park) and Lot 739 (where a waiting shed for commuters is located).
The lot is geographically bounded on the north by Lot 1 of Plan II-5201-A and on the south by the national road.
Immediately in front of Lot 736 stands the Mary Help of Christians Seminary, which occupies Lot 1; this lot is titled in the name of the Roman Catholic Archbishop of Lingayen-Dagupan (respondent) under Transfer Certificate of Title No. 6375, with an annotation indicating that both the respondent and the Municipality of Binmaley claim ownership of Lot 3.

In 1958, the seminary’s Rector ordered the construction of a concrete fence along Lot 736’s boundary with the national road to repel caretelas (horse-drawn vehicles), due to the objectionable smell of horse manure affecting the priests.
The concrete fence was constructed with openings (east, west, and center) and lacked a dedicated gate, thereby allowing unrestricted passage by the public at any time.

On December 22, 1997, the Sangguniang Bayan of Binmaley passed Resolution No. 104 which converted Lot 736 from an institutional lot to a commercial lot.
Concurrently, Resolution No. 105 authorized the municipal mayor to enter into a 25-year lease contract with the Rural Bank of Anda for a 252-square meter portion of Lot 736.
Shortly thereafter, in December 1997, Fr. Arenos, the seminary director, discovered that a temporary “sawali” (woven bamboo or similar material) fence was being erected, encroaching on Lot 736.

In January 1998, Municipal Mayor Rolando Domalanta visited the seminary to discuss the sawali fence construction, and an agreement was reached with Fr. Arenos to temporarily halt the building for the Rural Bank of Anda.
On March 24, 1998, the respondent formally requested Mayor Domalanta to remove the sawali fence and restore the original concrete fence.
By May 20, 1998, the mayor communicated that while construction would resume for the Rural Bank building, he remained open to further discussions regarding the issue.

On June 1, 1998, the respondent filed a complaint for the abatement of illegal constructions, seeking an injunction and damages, accompanied by a request for a writ of preliminary injunction.
The Regional Trial Court (RTC) issued the writ of preliminary injunction on August 24, 1998.
On January 4, 2000, the RTC rendered a decision ordering the defendants to restore the concrete fence, remove the sawali fence, and, initially, to pay litigation expenses, attorney’s fees, and other costs (awards later modified by the Court of Appeals).

The trial court found that Lot 736 is not covered by any Torrens title in the name of either the respondent or the Municipality of Binmaley, thus classifying it as public land.
Evidence showed that the lot was commonly used by the public as a pathway, parking area, and playground.
It was determined that neither the respondent nor the municipality could rightfully claim private ownership over a property that is part of the public domain.

Whether Resolution Nos. 104 and 105, which converted Lot 736 to a commercial lot and authorized a 25-year lease, were enacted within the legal authority of the Sangguniang Bayan of Binmaley.
Whether these resolutions are valid given that Lot 736 is deemed a property of public dominion.

Whether the respondent’s claim based on alleged open, continuous, adverse, and uninterrupted possession is sufficient to establish private ownership over Lot 736.
Whether the documentation presented by the Municipality of Binmaley (such as the Property Identification Map, Tax Mapping Control Roll, and Lot Data Computation) constitutes valid evidence of ownership.

Whether a municipal body has the constitutional and statutory authority to convert public domain land to a commercial status.
Whether leasing a portion of the public domain to a private entity, such as the Rural Bank of Anda, violates the principles encapsulated in the regalian doctrine.