GR 49; (May, 1903) (Digest)
G.R. No. 49 : May 11, 1903
THE MUNICIPALITY OF ANTIPOLO, plaintiff, vs. THE COMMUNITY OF CAINTA, defendant.
FACTS:
The Community of Cainta, through its representative Pablo de la Cruz, filed a petition in 1893 with the Spanish colonial civil administration. Cainta sought the return of ninety-two quiñones of common lands it claimed to own, which had been leased long ago to the Municipality of Antipolo for an annual rent. Cainta alleged that the lease was for an indefinite period and that the rent, originally paid to Cainta and later to the government, ceased in 1887. Cainta argued that upon cessation of payment, the lands should be returned. An administrative investigation followed, where both towns admitted they had no written contract concerning the lease. The Spanish administrative authorities ultimately issued a resolution on February 28, 1896, ordering the termination of the lease and the return of the lands’ dominium utile (beneficial ownership) to Cainta, effectively granting it full ownership. Antipolo challenged this administrative resolution before the contentious administrative court. The case was later transferred to the Supreme Court upon the abolition of that court.
ISSUE:
Whether the Spanish administrative authorities (and subsequently the contentious administrative court) had jurisdiction to adjudicate the dispute over the ownership and possession of the lands between the municipalities of Cainta and Antipolo.
RULING:
The Supreme Court declared the administrative resolution of February 28, 1896, and all related proceedings, null and void. The Court held that the dispute was beyond the jurisdiction of the administrative authorities. The case involved a question of ownership and possession (a revindicatory action) arising from an alleged contract of lease between two municipalities, which dated back to a very remote period. Under the applicable laws, contentious administrative jurisdiction was limited to contracts entered into by the administration for public service or public works. Disputes of a civil character concerning property rights, such as this one, fell exclusively within the jurisdiction of the ordinary courts. The Court found that the administrative order which resulted in the ouster of Antipolo from the lands was illegal. The proper forum for resolving the substantive issue of ownership or right to possession was the regular judicial system, not the administrative agencies.