Case Summary (G.R. No. 155051)
Applicable Law
The ruling is grounded in the provisions of the 1987 Philippine Constitution and relevant jurisprudence regarding public dominion and property rights.
Facts of the Case
The case revolves around Lot 736, which is a 1,300 square meter parcel located in Binmaley, Pangasinan. This lot is part of a larger Lot 3, which comprises other lots, including Imelda's Park and a waiting shed. The respondent, the Roman Catholic Archbishop of Lingayen, holds title to an adjacent lot under Transfer Certificate of Title No. 6375, which also indicates that the ownership of Lot 3 is under dispute between the archbishop and the Municipality of Binmaley.
In December 1997, the Sangguniang Bayan of Binmaley passed two resolutions converting Lot 736 from institutional to commercial and allowing the Rural Bank of Anda to lease part of it. However, this lease was contested when the director of the seminary adjacent to Lot 736 discovered unauthorized fencing by the bank, prompting a series of discussions and a eventual civil complaint by the respondent.
Rulings in Lower Courts
The trial court ruled in favor of the respondent, making the preliminary injunction permanent, ordering the restoration of the original concrete fence, and awarding damages. On appeal, the Court of Appeals affirmed the ruling but deleted the monetary awards, reinforcing that Lot 736 is a property of public dominion, appropriate for public use and thereby ineligible for private appropriation.
Issue
The primary issue at hand is the validity of Resolutions Nos. 104 and 105 enacted by the Sangguniang Bayan of Binmaley that facilitated the conversion and leasing of Lot 736.
Court's Analysis
The Supreme Court, upon review, affirmed both lower court decisions, emphasizing that neither the respondent nor the Municipality of Binmaley presented a valid title to Lot 736. Testimonies indicated its public use as a pathway, with no evidence provided by either party to substantiate claims of ownership.
The Court highlighted that public lands, characterized as property of public dominion, cannot be privately owned or
...continue readingCase Syllabus (G.R. No. 155051)
The Case
- This case is a petition for review concerning the Decision dated 15 October 2001 and the Resolution dated 23 August 2002 of the Court of Appeals in CA-G.R. CV No. 66478.
- The review revolves around the validity of certain resolutions passed by the Sangguniang Bayan of Binmaley, Pangasinan regarding the disputed Lot 736.
The Facts
- Lot 736, located in the Poblacion of Binmaley, Pangasinan, covers approximately 1,300 square meters and is part of Lot 3, which includes Cadastral Lot 737 (known as Imelda's Park) and Lot 739 (a waiting shed for commuters).
- Lot 3 is bordered to the north by Lot 1 of Plan II-5201-A, owned by the Roman Catholic Archbishop of Lingayen (respondent), under Transfer Certificate of Title No. 6375 (TCT 6375).
- An annotation on TCT 6375 indicates a claim of ownership over Lot 3 by both the respondent and the Municipality of Binmaley.
- In 1958, a concrete fence was constructed by the Rector of the seminary to separate Lot 736 from the national road due to nuisances caused by parked vehicles.
- The concrete fence features openings and has no gate, allowing public access at all times.
- On 22 December 1997, the Sangguniang Bayan passed Resolution No. 104 converting Lot 736 from an institutional to a commercial lot, and Resolution No. 105 authorized the municipal mayor to lease part of Lot 736 to the Rural Bank of Anda for 25 years