Baguio Citizens Action Inc. v. City Council and City Mayor of Baguio
REITERATIONFacts
The Antecedents: The underlying dispute concerns the validity of Baguio City Ordinance No. 386, enacted on February 23, 1967. This ordinance declared all registered squatters on public lands within Baguio townsite, not earmarked for public use, as bona fide occupants. It further stipulated that these lands would be embraced within a City Government Housing Project, provided for the issuance of building permits, the dropping of pending court cases against squatters, and the awarding of lots to squatters by direct sale through Presidential Proclamation. The ordinance also aimed to disregard minimum lot area requirements in congested areas and set terms for payment and survey expenses. Procedural History: The case originated as a petition for declaratory relief filed by Baguio Citizens Action Inc. and Junior Chamber of Baguio City, Inc. in the Court of First Instance of Baguio, Branch II, seeking to declare Ordinance No. 386 invalid and illegal ab initio. The respondents, the City Council and City Mayor of Baguio, filed motions to dismiss, which were denied. However, the trial court ultimately dismissed the petition, citing three grounds: (1) a prior declaration of the ordinance's validity by another branch of the same court in a criminal case; (2) the non-joinder of the squatters as parties, deemed a jurisdictional defect; and (3) the court's discretion to refuse a declaration if it would not terminate the controversy or was not necessary or proper. The Petition: The petitioners-appellants perfected an appeal to the Supreme Court under Rule 42, prior to the approval of Republic Act No. 5440. They argue that the trial court erred in dismissing their petition. Specifically, they contend that the non-inclusion of the squatters was not a jurisdictional defect, as the primary issue was the City Council's power to enact the ordinance, and any determination would be binding on the parties already involved. They further assert that the ordinance is a patent nullity, as squatting on public land is unlawful and cannot be legitimized by municipal ordinance, citing previous Supreme Court pronouncements against squatting and emphasizing the state's exclusive power over public domain disposition.
Issue(s)
Whether the Court of First Instance erred in dismissing the petition for declaratory relief, and whether the non-joinder of the squatters as parties to the suit was a jurisdictional defect. Whether Ordinance No. 386 of Baguio City is valid.
Ruling
The Supreme Court reversed the decision of the Court of First Instance, declared Ordinance No. 386 null and void, and ordered it to be without force and effect.
Ratio Decidendi
On the dismissal of the petition for declaratory relief and the non-joinder of parties: The Court held that the non-inclusion of the squatters as party defendants did not defeat the jurisdiction of the Court of First Instance. While Section 2 of Rule 64 requires all persons who have an interest affected by the declaration to be made parties, it does not state that non-joinder is a jurisdictional defect. The declaration would not prejudice rights of persons not parties to the action. Furthermore, the Court may refuse to make a declaration if it would not terminate the uncertainty or controversy. In this case, the City Council, as the body that passed the ordinance, was already a party, and any determination would be binding on the squatters as their rights were derived from the ordinance. The Court distinguished this from Degala v. Reyes, where a necessary party whose absence would render a judgment futile was not impleaded. On the validity of Ordinance No. 386: The Court declared Ordinance No. 386 a patent nullity. The ordinance considered squatters of public land as bona fide occupants and provided for their acquisition of lots through direct sale. The Court reiterated its pronouncement in City of Manila v. Garcia that squatting is unlawful and cannot be elevated into a lawful act by official acquiescence, as it fosters moral decadence and disrespect for the law. The Court emphasized that the State possesses plenary power to determine recipients of public domain, and the Director of Lands has exclusive control over its disposition. The ordinance, by attempting to dispose of public land without prior legislative authority and in contravention of established laws, usurped powers vested in national authorities. The Court also rejected the justification that the ordinance was an act of social justice, citing Astudillo vs. Board of Directors of PHHC, which held that social readjustment policies cannot lay aside moral standards or favor usurpers. The Court noted the government's militant policy against squatters, as evidenced by Letter of Instruction No. 19.
Main Doctrine
An ordinance that declares all registered squatters on public land as bona fide occupants and provides for their acquisition of lots through direct sale, without prior legislative authority and in contravention of laws governing public land disposition, is a patent nullity. The State possesses plenary power to determine recipients of public domain, and the Director of Lands has exclusive control over its disposition.