Salas V Jarencio (1972) Ponente: Esguerra, J.

Legal Doctrine: 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 Facts: February 24, 1 1 !the 4th "ranch of the #ourt of First $nstance of %anila, acting as a land registration court, rendered &udgment in #ase 'o( 1), *(+(R(,( Record 'o( 111, declaring the #ity of %anila the owner in fee simple of a parcel of land -nown as +ot 'o( 1, "loc- ../ of the #adastral Survey of the #ity of %ani1a, containing an area of ,0) () square meters, more or less( 1ugust 21, 1 22 34itle 'o( 452 issued on in favor of the #ity of %anila after the land in question was registered in the #ity6s favor( 4he 4orrens 4itle expressly states that the #ity of %anila was the owner in 6fee simple6 of the said land September 22, 1 02!the %unicipal "oard, presided by then 7ice8%ayor 1ntonio 7illegas, requested 9:is ;xcellency the <resident of the <hilippines to consider the feasibility of declaring the city property bounded by Florida, San 1ndres and 'ebras-a Streets, under 4ransfer #ertificate of 4itle 'os( 2..4. and 2..4/, containing an area of /,4.2 square meters, as patrimonial property of the City of Manila for the purpose of reselling these lots to the actual occupants thereof 4he said resolution of the %unicipal "oard of the #ity of %anila was officially transmitted to the <resident of the <hilippines the following day, to which a copy was furnished to the Senate and :ouse of Representatives of the #ongress of the <hilippines( =une 22, 1 04!R1 411) was passed by the Senate and approved by the <resident pursuant to the request( Such bill was enacted for social &ustice purposes, that they be sold to their currently landless occupants( "ut due to reasons which do not appear in the record, the #ity of %anila made a complete turn8about, for on >ecember 22, 1 00, 1ntonio =( 7illegas, in his capacity as the #ity %ayor of %anila and the #ity of %anila as a duly organi?ed public corporation, brought an action for in&unction and@or prohibition with preliminary in&unction to restrain, prohibit and en&oin the herein appellants, particularly the *overnor of the +and 1uthority and the Register of >eeds of %anila, from further implementing Republic 1ct 'o( 411), and praying for the declaration of Republic 1ct 'o( 411) as unconstitutional( Issues an Decisions: 1( $s the property involved private or patrimonial property of the #ity of %anilaA !", it is the property of the State( 2( $s Republic 1ct 'o( 411) valid and not repugnant to the #onstitutionA #ES, it is valid( $atio: 1. Is t%e &ro&ert' in(ol(e &ri(ate or &atri)onial &ro&ert' o* t%e +it' o* ,anila- !", it is t%e &ro&ert' o* t%e State. 4he rule is that when it comes to property of the municipality which it did not acquire in its private or corporate capacity with its own funds, the legislature can transfer its administration and disposition to an agency of the 'ational *overnment to be disposed of according to its discretion(

4he 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( 4he #ity of %anila, although declared by the #adastral #ourt as owner in fee simple, has not shown by any shred of evidence in what manner it acquired said land as its private or patrimonial property( 4he presumption is that such land came from the State upon the creation of the municipality( 4hat it has in its name a registered title is not questioned, but this title should be deemed to be held in trust for the State as the land covered thereby was part of the territory of the #ity of %anila granted by the sovereign upon its creation 4herefore, the land in question pertains to the State and the #ity of %anila merely acted as trustee for the benefit of the people therein for whom the State can legislate in the exercise of its legitimate powers( 2. Is $e&u.lic /ct !o. 0111 (ali it is (ali . an not re&ugnant to t%e +onstitution- #ES,

#onsequently, the #ity of %anila was not deprived of anything it owns, either under the due process clause or under the eminent domain provisions of the #onstitution( $f it failed to get from the #ongress the concession it sought of having the land involved given to it as its patrimonial property, the #ourts possess no power to grant that relief( Republic 1ct 'o( 411) does not, therefore, suffer from any constitutional infirmity( -Katrina Magallanes-