Case Summary (G.R. No. L-31249)
Ordinance Description: Regulation of Subdivision Plans in Dagupan City
The ordinance in question, Ordinance No. 22, regulated subdivision plans over parcels of land in Dagupan City. It mandated that every proposed subdivision plan be submitted first to the City Engineer prior to approval or verification by the Bureau of Lands or the Land Registration Commission. The City Engineer was tasked with ensuring no encroachment on public domain, compliance with zoning ordinances, and other relevant regulations. A service fee of P0.03 per square meter was to be charged. The ordinance further prohibited the Register of Deeds from allowing registration of subdivisions without a certification from the City Engineer confirming submission and orderliness of the plan. Penalties for violations included fines up to P200 or imprisonment up to six months, or both.
Lower Court Ruling: Ordinance Declared Null and Void
The Court of First Instance of Pangasinan annulled the ordinance, finding that it conflicted with Section 44 of Act No. 496. The court noted that Act No. 496 governed subdivision plans and neither required submission to the City Engineer nor authorized additional fees or certification prior to registration. The ordinance imposed extra requirements that effectively amended a general national law without proper authority. The imposition of penalties not contemplated by the national law was also a ground for nullity. While acknowledging the ordinance’s laudable objective of preventing unauthorized registration of government lands, the court held that local legislation could not restrict rights granted by overarching national statutes.
Supreme Court’s Affirmation and Legal Analysis
The Supreme Court affirmed the lower court decision, emphasizing constitutional principles concerning the exercise of police power by local governments. It highlighted the risk of local ordinances undermining national laws by adding unauthorized requirements, which could lead to fragmentation and inconsistency in legal standards across jurisdictions. The Court warned against excessive local interference under the guise of police power, asserting that while regulation is necessary for the common good, it must not erode individual freedoms without clear legislative mandate. The government’s police power must be exercised with restraint to prevent arbitrary or oppressive intrusions into private rights.
Emphasis on Individual Rights and Police Power Limits
The ruling underscored the importance of balancing communal welfare with individual rights, cautioning that "general welfare" shoul
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Background and Nature of the Case
- This is a petition for certiorari challenging a decision by the Court of First Instance (CI) of Pangasinan.
- The CI had annulled an ordinance enacted by the Municipal Board of Dagupan City.
- The ordinance in question aimed at regulating subdivision plans over parcels of land within Dagupan City.
- Petitioners: Salvador Villacorta (City Engineer) and Juan S. Caguioa (Register of Deeds of Dagupan City).
- Respondents: Gregorio Bernardo and Hon. Macario Ofilada (Judge of the Court of First Instance of Pangasinan).
Substance of the Ordinance No. 22
- The ordinance was entitled “An Ordinance Regulating Subdivision Plans Over Parcels of Land in the City of Dagupan.”
- Section 1: Required all proposed subdivision plans to be submitted first to the City Engineer for review to ensure:
- No encroachment on public domain.
- Compliance with zoning ordinances and pertinent rules and regulations.
- Section 2: Imposed a service fee of P0.03 per square meter on every lot resulting from subdivisions, to be collected by the City Engineer’s Office.
- Section 3: Prohibited the Register of Deeds from registering any subdivision plan unless there was prior written certification from the City Engineer confirming submission and orderliness of the plan.
- Section 4: Established penalties for violation—fine up to P200, imprisonment for up to 6 months, or both, at the discretion of the judge.
- Section 5: Stated the ordinance would take immediate effect upon approval.
Grounds for Annulment by the Court of First Instance
- The CI declared the ordinance null and void for several legal reasons:
- Conflict with Section 44 of Act 496: The ordinance imposed requirements not found in the national law.
- Specifically, the ordinance’s requirement in Section 1 for prior submission to the City Engineer was not mandated by Act 496.
- The service fee in Section 2 was not recognized by the national law, which w