G.R. No. 184869 – 645 Phil. 282 – Political Law – Constitutional Law – Bill of Rights – Due Process; Judicial Due Process – Right to Be Heard
Civil Law – Law on Property – Inalienable Land
In 1958, President Carlos Garcia declared the Central Mindanao University as the owner of a 3,401 hectare lot in Musuan, Bukidnon. In 2003, President Gloria Macapagal-Arroyo issued Presidential Proclamation No. 310 which declared that 310 hectares of CMU’s land is now owned by indigenous people.
CMU filed a petition with the Malaybalay RTC to question the constitutionality of the proclamation. The defendants filed a motion to dismiss on the ground that the Malaybalay RTC has no jurisdiction; that it was the Manila RTC that has jurisdiction because the presidential act being questioned was done in Manila.
The Malaybalay RTC heard the motion to dismiss (a preliminary matter) filed by the defendants and thereafter it ruled that it has no jurisdiction but at the same time it declared that PP No. 310 is constitutional on the ground that CMU merely holds the land in behalf of the State and the State, as the true owner, may choose to re-allocate the land.
CMU appealed the ruling to the Court of Appeals. The CA dismissed the appeal on the ground that it was improperly filed and that CMU should have filed its appeal directly with the Supreme Court via a petition for review on certiorari considering that the CMU raised pure questions law – bearing mainly on the constitutionality of PP No. 310.
ISSUE: Whether or not the Court of Appeals is correct.
HELD: No. When CMU filed its appeal with the CA, it did not raise purely questions of law. CMU also raised the issue that it was deprived due process when the Malaybalay RTC already ruled on the constitutionality of PP No. 310. What the Malaybalay RTC heard was the motion to dismiss and the issue raised there by the defendant was whether or not the Malaybalay RTC has jurisdiction – not constitutionality. That being, neither party presented their respective arguments and pieces of evidence as regards the constitutionality of PP No. 310. Hence, the CA’s ruling that CMU raised purely questions of law is in violation of CMU’s right to due process. The CA should have determined whether or not CMU was deprived by Malaybalay RTC of due process when it immediately ruled on the constitutionality of PP No. 310 when in fact, what was being heard at that stage of the trial was whether or not the Malaybalay RTC has jurisdiction.
The SC did not remand the case to the CA or to the RTC. Nevertheless, the SC chose to rule on the constitutionality of PP No. 310 to avoid further delay. The SC ruled that PP No. 310 is unconstitutional. When Pres. Garcia declared that the Musuan lot is a property of the State in the name of CMU, it was a declaration that the lot is an inalienable land. Hence, it cannot be included in the parcels of land to be distributed to indigenous people (note, the distribution was not by way of ancestral claim).
