Case Digest (G.R. No. 174964) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Sangguniang Panlalawigan of Bataan v. Congressman Enrique T. Garcia, Jr., the Province of Bataan (petitioner) owned two parcels of land (Lot Nos. 2193 and 2194) registered under Original Certificate of Title No. N-182, measuring approximately 1,222 sq m and 10,598 sq m, respectively. These lands were occupied by two state-run schools: the Bataan Community Colleges (BCC) and the Medina Lacson de Leon School of Arts and Trades (MLLSAT). On February 26, 1998, Congress enacted Republic Act No. 8562, authored by Congressman Garcia, converting MLLSAT into the Bataan Polytechnic State College (BPSC) and integrating BCC therein. Section 24 declared all government-occupied parcels as property of BPSC, to be titled accordingly, reverting to the Province if the college ceased to exist. Despite formal request, the Provincial Governor and Sangguniang Panlalawigan declined to transfer titles. Consequently, Congressman Garcia, BPSC faculty, concerned students, and the BPSC Board of Trustees Case Digest (G.R. No. 174964) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Land Registration and Occupancy
- Lot Nos. 2193 (1,222 sq m) and 2194 (10,598 sq m) in the Bataan Cadastre were registered under Original Certificate of Title No. N-182 in the name of the Province of Bataan.
- The lots were occupied by two state-run schools: Bataan Community Colleges (BCC) and Medina Lacson de Leon School of Arts and Trades (MLLSAT).
- Legislative Conversion and Title Transfer Request
- Republic Act No. 8562 (Feb. 26, 1998), authored by Congressman Garcia, converted MLLSAT into Bataan Polytechnic State College (BPSC) and integrated BCC.
- Section 24 of R.A. No. 8562 declared all government lands occupied by MLLSAT and BCC as property of BPSC, to be titled under its name, reverting to the Province if the college ceased to exist.
- Congressman Garcia requested the Governor and Sangguniang Panlalawigan of Bataan to transfer titles to BPSC; no action was taken.
- Judicial Proceedings
- Petitioners (Congressman Garcia, faculty, students, and later the BPSC Board of Trustees) filed a Special Civil Action for Writ of Mandamus (Civil Action No. 7043) in RTC Balanga, Bataan, to compel transfer of title.
- Respondents (Governor and Sangguniang Panlalawigan) challenged standing and asserted the lots were patrimonial property of the Province, mortgaged to Land Bank of the Philippines (LBP), thus protected against transfer without due process and just compensation.
- Decisions Below
- RTC Decision (Nov. 29, 2002): Granted writ of mandamus, ordering delivery of owner’s duplicate title, execution of deed of conveyance, and transfer of registration to BPSC.
- Court of Appeals Decision (Feb. 7, 2006): Affirmed RTC, ruling that:
- Petitioners failed to prove patrimonial acquisition by the Province; lots presumed public domain held in trust for the State.
- Mortgage lien to LBP must continue on new BPSC title with LBP’s consent.
- BPSC is real party in interest under Section 24, R.A. No. 8562.
Issues:
- Whether the subject lots are patrimonial property of the Province of Bataan, hence not transferable without due process and just compensation.
- Whether a writ of mandamus may issue to compel transfer of said lots absent due process and just compensation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)