Law School Noob: [CASE DIGEST] Salas v. Jarencio (G.R. No. L-29788)

Wednesday, September 29, 2021

[CASE DIGEST] Salas v. Jarencio (G.R. No. L-29788)

August 30, 1972

FACTS:

Republic Act 4118 was signed into law for the purpose of allowing the Land Tenure Authority to sell a 7,450 sqm property in Manila to the tenants thereof.

Mayor Villegas of Manila brought an action for injunction and/or prohibition with preliminary injunction to restrain the Governor of the Land Authority and the Register of Deeds from further implementing RA No. 4118 and praying for the declaration of RA No. 4118 as unconstitutional.

The Manila Mayor contended that the subject property belonged to the City by virtue of a TCT issued in the name of the City of Manila by the Court of First Instance of Manila in 1919.

ISSUE:

Whether the subject land is the patrimonial property of the City of Manila. -- NO.
Whether RA No. 1148 is constitutional. -- YES.

HELD:

The Supreme Court held that there was no evidence to show that the City of Manila had purchased the property with its own funds. The City of Manila, although declared by the Cadastral Court 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. The presumption is that such land came from the State upon the creation of the municipality. That 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 City of Manila granted by the sovereign upon its creation.

Properties which the municipality did not acquire in its private or corporate capacity with its own funds is presumed to be owned by the State upon the creation of the municipality.

Further, 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 National Government to be disposed of according to its discretion. 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.

As for RA No. 1148, the same was enacted upon formal written petition of the Municipal Board of Manila in the form of a legally approved resolution. In implementing the provisions of RA No. 4118, the officials of the City of Manila were duly informed and due process was observed in the reversion of the property to the National Government. The City of Manila was not deprived of anything it owns, either under the due process clause or under the eminent domain provisions of the Constitution.

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