Central Mindanao University v. Executive Secretary
REITERATIONFacts
The Antecedents: Petitioner Central Mindanao University (CMU), a state-owned educational institution, was initially granted 3,401 hectares of public land in 1958 for its use as a school site. CMU eventually obtained titles for 3,080 hectares of this land. In 2003, Presidential Proclamation 310 was issued, which sought to take 670 hectares from CMU's registered lands for distribution to indigenous peoples and cultural communities in the area. Procedural History: CMU filed a petition for prohibition with the Regional Trial Court (RTC) of Malaybalay City, seeking to nullify Presidential Proclamation 310. The respondents, including the Executive Secretary and the National Commission on Indigenous Peoples (NCIP), moved to dismiss the case for lack of jurisdiction, arguing that the RTC of Manila had jurisdiction over official acts of the Executive Department. The RTC initially denied this motion but later granted a partial reconsideration, dismissing the case for lack of jurisdiction while simultaneously ruling that the proclamation was constitutional. CMU appealed to the Court of Appeals (CA), which dismissed the appeal, holding that the issues raised were pure questions of law and thus should have been filed directly with the Supreme Court. CMU then filed the present petition for review. The Petition: CMU seeks review of the CA's decision, arguing that the CA erred in dismissing its appeal on the ground of raising pure questions of law. CMU contends that the RTC improperly dismissed its case for lack of jurisdiction while also ruling on the merits, and that the CA should have addressed the procedural due process issue. The core of the petition, however, addresses the constitutionality of Presidential Proclamation 310, asserting that the lands reserved for CMU are inalienable for educational and research purposes, as established in prior jurisprudence and protected by the Indigenous Peoples' Rights Act.
Issue(s)
Whether or not the Court of Appeals erred in not finding that the Regional Trial Court erred in dismissing CMU's action for prohibition for lack of jurisdiction and simultaneously ruling that Presidential Proclamation 310 is valid and constitutional. Whether or not the Court of Appeals correctly dismissed CMU's appeal on the ground that it raised purely questions of law proper for a petition for review filed directly with the Supreme Court. Whether or not Presidential Proclamation 310 is valid and constitutional.
Ruling
The Court GRANTS the petition, SETS ASIDE the decision and resolution of the Court of Appeals, and DECLARES Presidential Proclamation 310 null and void for being contrary to law and public policy.
Ratio Decidendi
On the first issue: The Court noted that a court may, in some instances, dismiss a case for lack of jurisdiction while also ruling on its merits, provided both conclusions lead to the dismissal of the action. However, the Court found this specific procedural point academic because the Court of Appeals had already dismissed CMU's appeal on a technical ground. On the second issue: The Court held that the Court of Appeals erred in dismissing CMU's appeal on the ground that it raised purely questions of law. While the issue of jurisdiction was a question of law, the claim that the RTC deprived CMU of due process by prematurely deciding the constitutionality of Presidential Proclamation 310 without proper hearing presented a factual issue that the CA should have adjudicated. The Court emphasized that whether the RTC indeed prematurely decided the constitutionality of the proclamation, thereby denying CMU its right to be heard, was a factual matter within the CA's purview. On the third issue: The Court ruled that Presidential Proclamation 310 is null and void. Citing its previous ruling in CMU v. Department of Agrarian Reform Adjudication Board (DARAB), the Court reiterated that lands reserved for state universities like CMU, especially those dedicated to agricultural and scientific research, are inalienable. These lands are set aside for the long-term functions and expansion of educational institutions and cannot be appropriated for other purposes. The Court further noted that the Indigenous Peoples' Rights Act (IPRA), enacted in 1997, explicitly mandates the recognition and respect of existing property rights, and CMU's ownership of the lands vested in 1958, predating the IPRA. Therefore, the subsequent transfer of these lands to indigenous peoples was contrary to both the nature of the reserved lands and the provisions of the IPRA.
Main Doctrine
Presidential Proclamation 310, which sought to take 670 hectares from Central Mindanao University's registered lands for distribution to indigenous peoples and cultural communities, was declared null and void. The Court held that lands reserved for educational purposes, particularly for state universities like CMU established to promote agriculture and industry, are considered inalienable and cannot be subject to appropriation for other purposes, especially when ownership has already vested. Furthermore, the Indigenous Peoples' Rights Act (IPRA) recognizes and respects existing property rights, and CMU's ownership of the lands predated the enactment of the IPRA.