Primary Holding

The Supreme Court held that the subject parcels of land are considered communal property of the State, held in trust by the Province of Bataan, and therefore are subject to the absolute control and disposition of the National Government through Congress. A writ of mandamus compelling the transfer of land titles to BPSC was correctly issued.

Background

The Province of Bataan owned land occupied by the Medina Lacson de Leon School of Arts and Trades (MLLSAT) and Bataan Community Colleges (BCC). Republic Act No. 8562 converted MLLSAT into Bataan Polytechnic State College (BPSC) and integrated BCC into it, declaring the lands occupied by these schools as property of BPSC and mandating the transfer of titles. The Province of Bataan refused to transfer the titles, claiming the lands were patrimonial property and mortgaged.

Facts

• 1. Lot Nos. 2193 and 2194, registered under the Province of Bataan, were occupied by state-run schools: Medina Lacson de Leon School of Arts and Trades (MLLSAT) and Bataan Community Colleges (BCC).
• 2. Republic Act No. 8562 converted MLLSAT to Bataan Polytechnic State College (BPSC) and integrated BCC, declaring the occupied lands as property of BPSC and mandating title transfer.
• 3. Congressman Garcia requested the Governor and Sangguniang Panlalawigan of Bataan to transfer titles, but they refused.
• 4. BPSC, along with faculty and students, filed a Special Civil Action for Mandamus to compel the transfer.
• 5. The Province of Bataan argued the lands were patrimonial property, could not be taken without due process and just compensation, and were mortgaged to Land Bank of the Philippines (LBP).

Arguments of the Petitioners

• 1. The subject lots are patrimonial properties of the Province of Bataan, not communal lands of the State.
• 2. Taking the patrimonial properties without due process and just compensation violates the Constitution.
• 3. A writ of mandamus cannot be issued to compel the transfer of patrimonial properties without due process.
• 4. Republic Act No. 8562 infringes on the State’s policy of local autonomy by diminishing the Province’s control over its properties.
• 5. The Province used the lands as collateral for loans with LBP, and the mortgage lien should be considered.
• 6. The Board of Trustees of BPSC previously acknowledged the Province's titles, indicating recognition of ownership.

Arguments of the Respondents

• 1. BPSC is the real party in interest and has standing to file the petition for mandamus based on Section 24 of R.A. No. 8562.
• 2. The subject lands are not patrimonial properties but are considered communal property of the State held in trust by the Province.
• 3. Republic Act No. 8562 validly transferred ownership of the lands to BPSC as an exercise of the State's power over public domain land.
• 4. Local autonomy does not extend to patrimonial properties acquired through public funds or originally belonging to the State.
• 5. The mortgage to LBP can be addressed by securing LBP’s consent and transferring the lien to the new titles.

Issues

• 1. Whether the subject parcels of land are patrimonial properties of the Province of Bataan, requiring due process and just compensation for taking.
• 2. Whether a writ of mandamus may be issued against the Petitioner to compel the transfer of the subject properties without due process of law and just compensation.

Ruling

• 1. The Supreme Court ruled against the Sangguniang Panlalawigan, affirming the CA and RTC decisions.
• 2. The Court reiterated the Regalian Doctrine, stating all lands of the public domain belong to the State.
• 3. Properties of municipal corporations, unless proven to be acquired with their private funds, are presumed to be held in trust for the State.
• 4. The Province of Bataan failed to prove the lands were acquired with their private funds, thus the presumption stands that they are communal properties of the State.
• 5. Republic Act No. 8562 did not violate local autonomy because the State retains ultimate control over public domain lands held in trust by local governments.
• 6. The writ of mandamus was properly issued to compel the transfer as R.A. No. 8562 explicitly mandates the transfer and BPSC is the real party in interest.
• 7. The mortgage to LBP does not prevent the transfer but requires securing LBP's consent and carrying over the lien to the new title.

Doctrines

• 1. Regalian Doctrine: All lands of the public domain belong to the State.
• 2. Public vs. Patrimonial Property of Local Governments: Properties of local governments are classified as either for public use or patrimonial. Properties for public use or devoted to governmental purposes are under the absolute control of Congress.
• 3. Communal Property Held in Trust: Lands titled to local governments but originally from the public domain or acquired through public funds are deemed held in trust for the State.
• 4. Writ of Mandamus: A writ commanding the performance of a specific legal duty, properly issued when there is a clear legal right and a corresponding duty to perform an act.
• 5. Local Autonomy vs. State Power: Local autonomy is limited and does not diminish the State's inherent power over public domain lands.

Key Excerpts

• 1. "Under the well-entrenched and time-honored Regalian Doctrine, all lands of the public domain are under the absolute control and ownership of the State."
• 2. "Regardless of the source or classification of land in the possession of a municipality, excepting those acquired with its own funds in its private or corporate capacity, such property is held in trust for the State for the benefit of its inhabitants, whether it be for governmental or proprietary purposes."

Precedents Cited

• 1. Salas, etc., et al. v. Hon. Jarencio, etc., et al.: Used to establish the principle that properties titled to municipal corporations can be considered communal property held in trust for the State if not proven to be acquired with private funds.
• 2. Province of Zamboanga del Norte v. City of Zamboanga, et al.: Cited to differentiate between public and patrimonial properties of local governments and to show that public properties are under absolute congressional control.
• 3. Cariño v. Insular Government: Cited to explain the historical basis of the Regalian Doctrine.
• 4. Hong Hok v. David: Cited to reiterate the Regalian Doctrine.
• 5. Rabuco v. Hon. Villegas: Used as a virtual reprise of Salas, further reinforcing the principle of communal property and State control.
• 6. Heirs of Mario Malabanan v. Republic of the Philippines: Cited regarding the definition of public dominion property.
• 7. The National Liga ng Mga Barangay v. Judge Paredes: Cited regarding the concept of supervision and control of the President over local governments.
• 8. Pimentel, Jr. v. Hon. Aguirre: Cited to differentiate between the President’s power of supervision and control over local governments.
• 9. Magtajas v. Pryce Properties Corp., Inc.: Cited to emphasize that municipal governments are still agents of the national government.
• 10. Unson vs. Lacson, et al.: Cited regarding the presumption of State origin for municipal lands absent proof of private acquisition.
• 11. City of Manila vs. Insular Government: Cited to explain the historical context of communal lands.
• 12. Republic of the Philippines v. Agunoy, Sr.: Cited for the definition of real party in interest in mandamus cases.

Statutory and Constitutional Provisions

• 1. 1987 Constitution, Article XII, Section 2: Defines State ownership over natural resources and lands of the public domain.
• 2. 1987 Constitution, Article X, Sections 2 and 3: Pertaining to local autonomy and the Local Government Code.
• 3. 1987 Constitution, Article X, Section 4: Regarding Presidential supervision over local governments.
• 4. 1987 Constitution, Article X, Sections 18 and 22: Pertaining to corporate powers of local government units.
• 5. 1935 Constitution, Article III, Section 1(2): Just compensation for taking private property.
• 6. 1935 Constitution, Article XIII, Section 1: Defining public domain.
• 7. Amended 1935 Constitution, Article XIII, Section 1: Defining public domain (cited in the decision as well, likely a typo referring to the same provision).
• 8. 1973 Constitution, Section 2, Article XII (and Section 8, Article XIV as referenced in footnote): Defines State ownership over natural resources and lands of the public domain.
• 9. 1997 Rules of Civil Procedure, Rule 65, Section 3: Conditions for issuing a writ of mandamus.
• 10. Civil Code, Articles 423 and 424: Classification of property of provinces, cities, and municipalities into property for public use and patrimonial property.
• 11. Civil Code, Article 420(2): Definition of property of public dominion.
• 12. Republic Act No. 8562, Section 24: Declaring lands occupied by MLLSAT and BCC as property of BPSC and mandating title transfer.
• 13. Local Government Code of 1991 (R.A. No. 7160), Sections 2, 18, and 22: Provisions on local autonomy and powers of local government units.