G.R. No. 174964. October 05, 2016.
SANGGUNIANG PANLALAWIGAN OF BATAAN, PETITIONER, VS. CONGRESSMAN ENRIQUE T. GARCIA, JR., MEMBERS OF THE FACULTY, CONCERNED STUDENTS AND THE BOARD OF TRUSTEES OF THE BATAAN POLYTECHNIC STATE COLLEGE, RESPONDENTS.

FACTS

Lot Nos. 2193 and 2194, registered under OCT No. N-182 in the name of the Province of Bataan, were occupied by state-run schools. Republic Act No. 8562, authored by respondent Congressman Garcia, converted these schools into the Bataan Polytechnic State College (BPSC). Section 24 of the law declared all government lands occupied by these schools to be property of BPSC, with a reversionary clause in favor of the province should the college cease to exist. Despite a formal request, the provincial government, through the Sangguniang Panlalawigan, refused to transfer the titles.
The respondents, including the BPSC Board of Trustees, filed a petition for mandamus to compel the transfer. The petitioner Province argued that the lots were its patrimonial property, acquired with corporate funds and even mortgaged to the Land Bank, and thus could not be taken without due process and just compensation. It also challenged the legal standing of the respondents. The Regional Trial Court granted the writ of mandamus, a decision affirmed by the Court of Appeals.

ISSUE

The core issues were: (1) whether the subject parcels of land are patrimonial properties of the Province of Bataan, and (2) whether a writ of mandamus may issue to compel their transfer without compensation.

RULING

The Supreme Court denied the petition and affirmed the lower courts. The Court ruled that the lots are not patrimonial property of the province but are owned by the State. Applying the Regalian doctrine, all lands of the public domain belong to the State, and evidence must be presented to overcome this presumption. The petitioner failed to prove that the province acquired the lots with its private corporate funds. Mere registration under the Torrens system in the name of the province does not convert state property into patrimonial property; it only confirms the province’s administrative control. The province holds such property in trust for the State.
Consequently, R.A. No. 8562, a valid exercise of legislative power, merely transferred administrative control of the state-owned property from one government instrumentality (the province) to another (BPSC). This does not constitute a “taking” of private property requiring due process and just compensation. The writ of mandamus was therefore proper to compel the performance of a ministerial duty mandated by law. The Court also noted that the mortgage lien with the Land Bank must be carried over to the new title issued to BPSC, protecting the bank’s interest. The BPSC was correctly deemed a real party in interest.