Case Summary (G.R. No. 174964)
Petitioner
Sangguniang Panlalawigan of Bataan (represented by the Governor and provincial officials).
Respondents
Congressman Enrique T. Garcia, Jr.; members of Bataan Polytechnic State College faculty; concerned students; Board of Trustees of the Bataan Polytechnic State College.
Key Dates
• Original Torrens registration of Lots 2193 and 2194: August 11, 1969.
• Enactment of R.A. No. 8562 converting Medina Lacson de Leon School and Bataan Community Colleges into Bataan Polytechnic State College: February 26, 1998.
• RTC decision granting writ of mandamus: November 29, 2002.
• CA decision affirming RTC: February 7, 2006.
• Supreme Court decision affirming CA: October 5, 2016.
Applicable Law
• 1987 Philippine Constitution (Article XII, Section 2; Article X on local autonomy)
• Republic Act No. 8562, Section 24
• Rules of Civil Procedure, Rule 65 on writs of mandamus
• Regalian Doctrine and related jurisprudence (Salas v. Jarencio, Zamboanga del Norte v. City of Zamboanga)
Land Ownership Dispute and Mandamus Relief
Lots 2193 (1,222 sq m) and 2194 (10,598 sq m) in the Bataan Cadastre were issued under OCT No. N-182 to the Province of Bataan but occupied by two state-run schools. R.A. No. 8562 declared these parcels the property of the newly created Bataan Polytechnic State College (BPSC) and directed their transfer. Petitioners refused, prompting respondents to seek a writ of mandamus compelling transfer and registration in BPSC’s name.
Regulatory Background under R.A. No. 8562
Section 24 of R.A. No. 8562 states that “all parcels of land belonging to the government occupied by the Medina Lacson de Leon School of Arts and Trades and the Bataan Community Colleges are declared to be the property of the Bataan Polytechnic State College and shall be titled under that name,” with reversion to the Province if the college ceases to exist or the land is no longer needed.
Procedural History
The Regional Trial Court of Bataan granted mandamus in 2002. The Province and Sangguniang Panlalawigan appealed, arguing (1) the land was patrimonial property of the Province entitled to due process and compensation, (2) existing mortgage liens prevented free transfer, and (3) respondents lacked real-party-in-interest status. The Court of Appeals affirmed in 2006. The Supreme Court granted review and affirmed.
Contentions of the Province of Bataan
- The Torrens-registered lots are patrimonial properties acquired with provincial funds, hence beyond Congress’s plenary power and protected by due process and just compensation.
- Existing Land Bank mortgage liens violate the non-impairment clause if the titles are transferred without preserving creditor rights.
- Respondents lack standing, as the Province remains the true owner entitled to avails of any suit.
Court of Appeals and RTC Decisions
Both courts held:
• The Province failed to prove acquisition with private or corporate funds; under Salas v. Jarencio, municipal or provincial title to public-domain land is held in trust for the State and subject to legislative disposition.
• Mortgage liens may remain; the Land Bank’s consent and annotation of lien on the new title will preserve creditor rights.
• BPSC is the real party in interest under Section 24 of R.A. 8562 and properly impleaded.
Issues for Resolution
I. Whether the parcels are patrimonial property of the Province, requiring due process and compensation before transfer.
II. Whether mandamus can compel transfer absent compensation or due process.
Regalian Doctrine and State Ownership
Under Article XII, Section 2 of the 1987 Constitution, all public-domain lands are owned by the State. The Regalian Doctrine vests absolute ownership in the State, subject to statutory grants. Title to public lands issued to local governments is presumptively held in trust for the State unless proven acquired privately.
Classification of Local Government Property
Civil Code Articles 423–424 and jurisprudence (Zamboanga del Norte) distinguish (a) public-use property, over which Congress has plenary power, from (b) patrimonial property acquired in a local government’s private capacity, protected by due process and just compensation. Public-domain lands titled to local units but not acquired with private funds remain public dominion property.
Presumption of Trust for State-held Titles
In Salas and Rabuco, the Court held that municipal lands titled without proof of private funding are communal lands held in trust for the State, subject to legislative power to reclassify and dispose of them to achieve social justice objectives. Registered title does not rebut that presumption.
Legislative Power over Communal Lands
Congress’s classification of public-domain property as disposable or public-use lies within its broad discretion and does not constitute expropriation requiring compensation, provided the property is held in trust and intended for national development or social justice programs.
Local Autonomy and Decentralization
While the 1987 Constitution (Article X, Sections 2–3) and the Local Government Code promote genuine local autonomy and devolution of powers, they do not affect the State’s dominical rights over public-domain property held in trust by local governments. Local au
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Procedural History
- Petition for Review on Certiorari under Rule 45 filed before the Supreme Court challenging the Court of Appeals’ Decision of February 7, 2006 in CA-G.R. SP No. 85902.
- CA had affirmed the Regional Trial Court of Bataan’s November 29, 2002 Decision granting a writ of mandamus in Special Civil Action No. 7043.
- Respondents below included Congressman Enrique T. Garcia, Jr., faculty members, students, and BPSC Board of Trustees; petitioner was the Sangguniang Panlalawigan of Bataan (with the Governor impleaded).
Antecedent Facts
- Lot Nos. 2193 (1,222 sq m) and 2194 (10,598 sq m) in the Bataan Cadastre were registered under OCT No. N-182 in the name of the Province of Bataan.
- These lots were occupied by the Bataan Community Colleges (BCC) and Medina Lacson de Leon School of Arts and Trades (MLLSAT), both state-run.
- Republic Act No. 8562 (February 26, 1998), authored by Congressman Garcia, converted MLLSAT into Bataan Polytechnic State College (BPSC) and integrated BCC therein.
- Section 24 of RA 8562 declared all government lands occupied by MLLSAT and BCC as property of BPSC, to be titled under its name, with reversion to the province if BPSC ceased to exist or no longer needed the lands.
- Petitioner Sangguniang Panlalawigan and the Governor failed to transfer title; respondents filed a special civil action for mandamus to compel transfer of title.
Issues
- Whether the subject parcels are patrimonial properties of the Province of Bataan that cannot be taken without due process and just compensation.
- Whether a writ of mandamus may issue against the petitioner to compel transfer of those parcels absent due process and just compensation.
RTC Decision
- RTC of Balanga, Bataan granted the writ of mandamus.
- Ordered delivery of the owner’s duplicate copy of OCT No. N-182, execution of a deed of conveyance to BPSC, and registration of title in BPSC’s name.
Court of Appeals Decision
- CA affirmed the RTC judgment.
- Held that petitioners failed to prove the lots were acquired wit