G.R. No. L-27247 April 20, 1983
IN THE MATTER OF THE PETITION FOR DECLARATORY JUDGMENT REGARDING THE VALIDITY OF ORDINANCE NO. 386 OF THE CITY OF BAGUIO, BAGUIO CITIZENS ACTION INC., and JUNIOR CHAMBER OF BAGUIO CITY, INC., petitioners-appellants, vs. THE CITY COUNCIL AND CITY MAYOR OF THE CITY OF BAGUIO, respondents-appellees.

FACTS

Petitioners Baguio Citizens Action Inc. and Junior Chamber of Baguio City, Inc. filed a petition for declaratory relief seeking to nullify Baguio City Ordinance No. 386. The ordinance, enacted in 1967, declared all squatters duly registered on public lands not earmarked for public use as bonafide occupants, embracing their lots as part of a City Government Housing Project. It effectively granted squatters de facto building permits, ordered the dismissal of pending court cases against them, and committed the city government to assist them in acquiring the lots through direct sale from the national government at minimal cost, disregarding standard lot area requirements.
The Court of First Instance (CFI) of Baguio, Branch II, dismissed the petition. The lower court cited three grounds: first, that another branch (Branch I) of the same CFI had already upheld the ordinance’s validity in a related criminal case, creating a conflict; second, that the squatters benefitted by the ordinance were indispensable parties who were not joined in the suit; and third, that the court had discretion to refuse declaratory relief if it would not practically help end the controversy.

ISSUE

The core issue is whether Baguio City Ordinance No. 386 is valid.

RULING

The Supreme Court declared Ordinance No. 386 null and void. The legal logic rests on the fundamental principle of separation of powers and the statutory authority over public lands. The Court held that the ordinance constitutes an unlawful usurpation of executive and administrative functions vested by law in the Director of Lands and, ultimately, the President. Under the Public Land Act ( Commonwealth Act No. 141 ), the administration, disposition, and alienation of lands of the public domain are powers exclusively granted to the national government through the Director of Lands. A city council, through a local ordinance, cannot preempt this authority by unilaterally declaring squatters as bonafide occupants entitled to direct sale of public land, effectively awarding them property rights. Such action encroaches upon the national government’s prerogative to classify and dispose of public lands.
Furthermore, the Court rejected the ordinance’s justifications of social justice and humanitarian treatment for squatters. It emphasized that government policy cannot favor or legitimize unlawful occupancy at the expense of legal order. Citing prior jurisprudence and official directives like Letter of Instruction No. 19, the Court affirmed a militant policy against squatting, stating that social readjustment cannot simply lay aside moral and legal standards to favor usurpers. The ordinance, therefore, contravenes established law and public policy. The procedural grounds for dismissal by the lower court were rendered moot by this substantive ruling on validity.