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

Case Summary (G.R. No. 175064)

Key Dates and Applicable Laws

June 18, 1948: Republic Act No. 305 took effect, converting the Municipality of Naga into the City of Naga.
June 16, 1955: Republic Act No. 1336 transferred the provincial capitol site from the City of Naga to the barrio of Palestina, Municipality of Pili, which was also established as the new provincial capital.
January 13, 1997: The City of Naga filed a Complaint for Declaratory Relief and/or Quieting of Title with the Regional Trial Court (RTC) seeking recognition of its administrative control of Plaza Rizal.
March 10, 1999: The RTC ruled in favor of the City of Naga.
June 28, 2004 and August 11, 2006: The Court of Appeals denied the Petition for Review filed by Camarines Sur.

The case is adjudicated under the 1987 Philippine Constitution and applicable laws including Republic Act Nos. 305 and 1336, and pertinent provisions of the Spanish Civil Code (1889) and the 1950 Civil Code regarding government property.

Nature of the Dispute

The legal issue focuses on whether the Province of Camarines Sur or the City of Naga should have administrative control and management over Plaza Rizal. Camarines Sur claims legal ownership based on possession, tax declarations, and historical control of the property, arguing that the property is patrimonial and thus under its control. Meanwhile, the City of Naga asserts that pursuant to RA No. 305, the territory, including public properties like Plaza Rizal, is within its jurisdiction, entitling it to administrative control as the governing local government unit.

Proceedings and Lower Court Decisions

The City of Naga’s complaint emphasizes that Camarines Sur’s management of Plaza Rizal despite its location within the City’s jurisdiction caused practical difficulties, including restrictions on improvements and use. The RTC dismissed Camarines Sur’s motion to dismiss the complaint, finding that the issues raised warranted full trial for resolution. Ultimately, the RTC ruled that the enactment of RA No. 305 effectively vested the City of Naga with administrative control over Plaza Rizal since the property lies within the City's defined territory.

Efforts by Camarines Sur to appeal the RTC decision were initially hampered by procedural defects and untimeliness. The Court of Appeals took cognizance of the matter and denied Camarines Sur’s Petition for Review, ruling that certiorari was improperly sought as a substitute for an appeal and affirming the RTC’s interpretation of RA No. 305.

Issues on Procedural Grounds: Petition for Review vs. Petition for Certiorari

The Supreme Court clarified that the Court of Appeals gravely abused its discretion when it treated Camarines Sur’s Petition for Review under Rule 45 as a Petition for Certiorari under Rule 65. The requisites for certiorari—such as the presence of grave abuse of discretion and lack of appeal as an adequate remedy—were not applicable because the petition was properly filed as a Petition for Review. The appellate court incorrectly dismissed the petition on the ground that certiorari could not substitute for a lost appeal, a principle inapplicable here.

Declaratory Relief and Justiciability

The Supreme Court affirmed that the City of Naga properly filed an action for declaratory relief since there was a justiciable controversy involving adverse interests between the City and the Province regarding the interpretation of Section 2, Article I of RA No. 305. The City sought a declaration of its right to the administrative control of Plaza Rizal based on its territorial jurisdiction. The Court found that the controversy was ripe for judicial determination as it affected legal rights and triggered actual conflict.

Classification of Plaza Rizal: Public Use Property

Examination of the nature of Plaza Rizal showed it to be a public plaza or park adorned with monuments and used for various public activities. Under the Spanish Civil Code (Art. 344) and the 1950 Civil Code (Art. 424), such properties are considered properties for public use, which are administered by local government units but are not private patrimonial properties.

Ownership and Administrative Control Under Applicable Laws

Prior to Naga’s conversion into a city, Camarines Sur had the right to administer Plaza Rizal as the territory was within its jurisdiction. However, with the enactment of RA No. 305 converting Naga into an independent city and defining its territorial jurisdiction to include Plaza Rizal, the administrative authority over the property vested in the City of Naga. The Province of Camarines Sur cannot claim Plaza Rizal as patrimonial property absent an express legislative grant. The existence of a tax declaration in the province’s name does not constitute conclusive proof of ownership but rather merely indicates a claim.

Final Ruling and Conclusions

The Supreme Court dismissed the petition filed by Camarines Sur, affirming that administrative control and supervision of Plaza Riza

Case Syllabus (G.R. No. 175064)

Background and Procedural History

This case involves a Petition for Certiorari filed under Rule 65 of the Rules of Court seeking to annul the decisions of the Court of Appeals dated 28 June 2004 and 11 August 2006, which denied the Petition for Review on Certiorari filed by the Province of Camarines Sur.
The central issue concerns a parcel of land known as Plaza Rizal, located within the territorial jurisdiction of the City of Naga, originally part of the Municipality of Naga, the former provincial capital of Camarines Sur.
Republic Act No. 305 (effective 18 June 1948) converted the Municipality of Naga into the City of Naga; Republic Act No. 1336 (approved 16 June 1955) transferred the provincial capitol site from the City of Naga to the Municipality of Pili.
The City of Naga filed a Complaint for Declaratory Relief and/or Quieting of Title in 1997, alleging that while Camarines Sur claimed ownership through tax declarations and exercised control over Plaza Rizal, the property is public domain and should be under the City's administrative control by virtue of its territorial jurisdiction established under RA 305.
The Regional Trial Court (RTC) ruled in favor of the City of Naga, holding that administrative control over Plaza Rizal rested with the City due to its territorial jurisdiction defined in RA 305.
Camarines Sur filed and lost motions for reconsideration, with the court denying appeals due to procedural defects, notably the failure to timely perfect an appeal.
The doctrine barring the use of certiorari as a substitute for a lost appeal was invoked by the Court of Appeals, which treated Camarines Sur’s Petition for Review as a Petition for Certiorari, resulting in denial and dismissal.

Nature and Character of Plaza Rizal

Plaza Rizal is described as a garden serving as the front lawn of the old provincial capitol site, with monuments and memorials constructed by the Provincial Government including those honoring the national hero, Ninoy Aquino, and President Manuel Quezon.
It contains facilities such as a skating ring, public TV, internet café, gazebo for public discourse, a giant chessboard, booths for trade fairs, ornamental plants, and lighting installations funded and maintained by the Province.
The plaza is thus classified as a property for public use, akin to a public park or promenade.

Legal Issues Presented

Whether the Court of Appeals gravely abused its discretion by treating a Petition for Review on Certiorari filed under Rule 45 as a Petition for Certiorari under Rule 65, thereby dismissing it for failure to allege grave abuse of discretion.
Whether the City of Naga’s filing of a Complaint for Declaratory Relief and/or Quieting of Title was proper considering the nature of the controversy.
Whether the administrative control and