Chanco v. Municipality of Romblon
REITERATIONFacts
The Antecedents: Plaintiff Alfredo Chanco applied to purchase a parcel of land from the Municipality of Romblon for P1.00 per square meter. The municipal council agreed to the sale. The provincial governor authorized the sale but at P1.20 per square meter, citing the last assessment. This modification was accepted by the council and the plaintiff, and the council agreed to execute a bill of sale. Procedural History: Following the municipal council's resolution to sell the land, several residents protested to the provincial board of Capiz. The provincial board of Capiz resolved to annul the municipal council's resolution of July 8, 1907. Subsequently, the municipal council of Romblon annulled its own resolution. The plaintiff then filed an action to compel specific performance of the alleged contract. The Appeal: The plaintiff appealed the trial court's decision dismissing his complaint, arguing that the contract was valid and binding. The sole assignment of error was that the court below erred in dismissing the complaint, as the contract involved was valid and binding.
Issue(s)
Whether the provincial board had the authority to annul a resolution of the municipal council for the sale of municipal land. Whether the annulment of the municipal resolution by the provincial board rendered the purported contract for the sale of land invalid and unenforceable.
Ruling
The Supreme Court affirmed the judgment of the trial court, holding that the provincial board had the authority to annul the municipal resolution and that the annulment rendered the purported contract unenforceable. The Court ruled that the plaintiff's claim for specific performance could not be maintained.
Ratio Decidendi
On Issue 1: The Court held that the provincial board had the authority to annul the resolution of the municipal council. Section 41 of the Municipal Code, as amended by Act No. 676, clearly conferred upon the provincial board the power to declare null and void any act, ordinance, or resolution of a municipal council if the board concluded that it violated the powers conferred by the Municipal Code. The Court rejected the argument that this power was limited to legislative or administrative acts and did not extend to contractual resolutions, stating that the law did not provide for such exceptions. The Court emphasized that all parties dealing with municipal councils were presumed to know this supervisory power. On Issue 2: The Court ruled that the annulment of the municipal resolution by the provincial board rendered the purported contract for the sale of land invalid and unenforceable. The agreement to sell the land was subject to the implied condition that it would be invalidated if the provincial board annulled the resolution before the actual execution of the sale. Since the provincial board did annul the resolution, and this annulment was carried out in accordance with the provisions of law, the plaintiff's claim for specific performance could not be sustained. The Court noted that even if the provincial board erred in its conclusion, its action, when taken in conformity with the law, was binding.
Main Doctrine
The Supreme Court affirmed that municipal resolutions, including those pertaining to the sale of real property, are subject to the supervisory and invalidating power of the provincial board. Even if a resolution appears to be within the general powers of the municipal council, the provincial board may annul it if it concludes that the resolution violates the powers conferred by the Municipal Code. Such annulment, when properly executed, renders the resolution null and void, preventing the enforcement of any purported contract arising from it, and all parties dealing with municipal councils are deemed to have knowledge of this supervisory power.