Rural Bank of Anda v. Roman Catholic Archbishop of Lingayen
REITERATIONFacts
The Antecedents: The case involves Cadastral Lot 736, a parcel of land in Binmaley, Pangasinan, with an area of approximately 1,300 square meters. Lot 736 is part of Lot 3, which also includes Cadastral Lot 737 (Imelda’s Park) and Lot 739 (waiting shed). Lot 1, on which the Mary Help of Christians Seminary is located, adjoins Lot 3 on the north. Lot 1 is titled in the name of respondent Roman Catholic Archbishop of Lingayen (respondent), with an annotation stating that ownership of Lot 3 is claimed by both respondent and the Municipality of Binmaley. In 1958, a fence was constructed separating Lot 736 from the national road to prevent parking. The fence had openings and no gate, allowing public passage. In December 1997, the Sangguniang Bayan of Binmaley passed Resolution Nos. 104 and 105, converting Lot 736 from an institutional lot to a commercial lot and authorizing the municipal mayor to lease a portion of it to petitioner Rural Bank of Anda, Inc. for 25 years. Fr. Arenos, director of the seminary, discovered a sawali fence being constructed on Lot 736 in December 1997. In January 1998, Mayor Domalanta agreed with Fr. Arenos to stop the construction of the Rural Bank of Anda building. On March 24, 1998, respondent requested the removal of the sawali fence and restoration of the concrete fence. On May 20, 1998, Mayor Domalanta informed respondent that construction would resume but expressed willingness to discuss the issue. Procedural History: On June 1, 1998, respondent filed a complaint for Abatement of Illegal Constructions, Injunction and Damages with Writ of Preliminary Injunction before the Regional Trial Court (RTC) of Lingayen, Pangasinan. The RTC issued a writ of preliminary injunction on August 24, 1998. On January 4, 2000, the RTC rendered a decision making the writ of preliminary injunction permanent, ordering the defendants to restore the concrete wall and remove the sawali fence at their expense, and awarding litigation expenses, attorney's fees, and costs to the respondent. On appeal, the Court of Appeals (CA) affirmed the RTC decision but deleted the monetary awards. The CA denied the motion for reconsideration filed by the Municipality of Binmaley and the Rural Bank of Anda. The Petition: Petitioner Rural Bank of Anda, Inc. filed a petition for review of the CA's Decision and Resolution.
Issue(s)
Whether Resolution Nos. 104 and 105 of the Sangguniang Bayan of Binmaley are valid.
Ruling
The petition has no merit. The Supreme Court affirmed the Decision dated 15 October 2001 and the Resolution dated 23 August 2002 of the Court of Appeals, denying the petition.
Ratio Decidendi
On the validity of Resolution Nos. 104 and 105: The Supreme Court held that Resolution Nos. 104 and 105 of the Sangguniang Bayan of Binmaley are void. Both respondent and the Municipality of Binmaley admitted they do not have title over Lot 736, and no document of ownership was presented to the Land Management Services. Respondent's claim of ownership based on alleged open, continuous, adverse, and uninterrupted possession was contradicted by testimony that Lot 736 was used by the public as a pathway, parking space, and playground. The documents presented by the Municipality of Binmaley, such as the Property Identification Map and Tax Mapping Control Roll, only showed it was a claimant, and its cadastral survey had not been approved. The Court reiterated the Regalian doctrine, which holds that the state owns all lands of the public domain, and that no public land can be acquired by private persons without a grant from the government. Since Lot 736 was used by the public in general as a pathway, parking space, and playground, and neither party proved ownership, it remains part of the public domain owned by the state. Consequently, the Sangguniang Bayan of Binmaley exceeded its authority in converting Lot 736 to a commercial lot and authorizing its lease, rendering the resolutions and the subsequent contract of lease void. The Court cited Hong Hok v. David for the principle that property must be held to be public domain in the absence of evidence of acquisition from the state.
Main Doctrine
Municipal corporations cannot appropriate to themselves public or government lands without prior grant from the government. Since Lot 736 is owned by the state, the Sangguniang Bayan of Binmaley exceeded its authority in passing Resolution Nos. 104 and 105. Thus, Resolution Nos. 104 and 105 are void and consequently, the contract of lease between the Municipality of Binmaley and the Rural Bank of Anda over a portion of Lot 736 is also void.