G.R. No. L-31249 - Villacorta vs. Bernardo

Petitioners Salvador Villacorta (City Engineer) and Juan S. Caguioa (Register of Deeds) of Dagupan City challenged a decision of the Court of First Instance of Pangasinan.
Respondents were Gregorio Bernardo and Hon. Macario Ofilada, Judge of the Court of First Instance of Pangasinan.

The Municipal Board of Dagupan City adopted Ordinance No. 22 titled "An Ordinance Regulating Subdivision Plans Over Parcels of Land in the City of Dagupan."
Key provisions of the ordinance:

Section 1: Subdivision plans must first be submitted to the City Engineer for review to ensure no encroachment on public domain and compliance with zoning and related regulations before submission for approval to national agencies.
Section 2: A service fee of P0.03 per square meter of every lot created or to be created by subdivision shall be charged by the City Engineer’s Office.
Section 3: The Register of Deeds shall not register subdivision plans without a written certification from the City Engineer confirming the plan was submitted and is in order.
Section 4: Violations shall be punished by a fine of up to P200, or imprisonment of up to six months, or both at the judge’s discretion.
Section 5: The ordinance was to take effect immediately upon approval.

The ordinance conflicted with Section 44 of Act 496, which governs subdivisions and registration of lands, as Act 496:

Does not require prior submission and approval by the City Engineer.
Does not authorize any service fee like the P0.03 per square meter imposed.
Does not require certification from the City Engineer before registration by the Register of Deeds.
Does not prescribe penalties for violations as established by the ordinance.

The ordinance imposed additional and inconsistent requirements exceeding the local government’s authority and intruded on a general law.
Despite the ordinance’s laudable purpose of preventing clandestine registration of government lands, it unlawfully impeded exercise of rights granted by national law, subordinating a general law to a local ordinance.

Whether or not the local ordinance regulating subdivision plans and imposing fees, certifications, and penalties is valid and enforceable.
Whether the ordinance unlawfully amended, contradicted, or added requirements beyond those provided under Section 44 of Act 496 on subdivision plans and land registration.
Whether local governments may enact ordinances that impose conditions or penalties that conflict with or limit the operation of a general national law.