Republic of the Philippines v City of Paranaque properties based on the assessment for delinquent real property tax for

for delinquent real property tax for the

GR No. | Date | Topic (what we need to focus on) | Ponente | Your Surname years 2001 and 2002.
4. PRA however, claims that reclaimed lands are still part of the public domain,
Petitioner: Republic of the Philippines, represented by the Philippine Reclamation
owned by the state, and therefore exempt from payment of real estate taxes.
Authority
Respondents: City of Paranaque
ISSUE/S:

Recit-Ready: The Public Estates Authority was created by PD 1084, and transformed
W/N reclaimed lands are part of the public domain, and are thus exempt from real
by EO 380 into the PRA. It is granted the authority to exercise all the powers and
estate tax – YES.
functions of the PEA relating to reclamation activities. The PRA reclaimed several
portions of land in the foreshore and offshore areas of Manila Bay. The Treasurer of
RATIO:
the City of Paranaque assessed the PRA real estate tax deficiency for the years 2001
and 2002. The PRA however, contends that reclaimed lands are part of the public
Issue 1: Article 420 of the Civil Code enumerates properties belonging to the State:
domain, and are thus exempt from real estate tax. The issue is whether or not
reclaimed lands form part of the public domain. The Court here held in the Art. 420. The following things are property of public dominion:
affirmative, saying that the lands subject of the litigation, are within the purview of
Article 420 of the new Civil Code as was ruled in the case of Chavez v Public Estates, (1) Those intended for public use, such as roads, canals, rivers,
the Court stated that foreshore and submerged areas are irrefutably part of the public torrents, ports and bridges constructed by the State, banks, shores,
domain, and are inalienable unless reclaimed, classified as alienable lands open to roadsteads, and others of similar character;
disposition and further declared no longer needed for public service. Reclaimed
lands such as the subject lands in issue are reserved lands for public use. They are (2) Those which belong to the State, without being for public use, and
properties of public dominion. The ownership of such lands remains with the State are intended for some public service or for the development of the
unless they are withdrawn by law or presidential proclamation from public use. national wealth.

Doctrine: Reclaimed lands such as the subject lands in issue are reserved lands for
public use. They are properties of public dominion. The ownership of such lands
remains with the State unless they are withdrawn by law or presidential proclamation
from public use.
FACTS:
1. The Public Estates Authority is a government corporation created by virtue of
PD 1084 to provide a coordinated, economical and efficient reclamation of
lands, and the administration and operation of lands belonging to, managed
and/or operated by the government with the object of maximizing their
utilization and hastening their development consistent with public interest.
2. On October 26, 2004, then President GMA issued EO 380, which transformed
PEA into PRA, which was granted the authority to exercise all the powers and
functions of the PEA relating to reclamation activities.
3. By virtue of its mandate, PRA reclaimed several portions of the foreshore and
offshore areas of Manila Bay, including those located in Paranaque City. The
Paranaque City Treasurer issued warrants of levy on PRA’s reclaimed
Here, the lands subject of litigation are reclaimed lands, specifically portions of the
foreshore and offshore areas of Manila Bay. These lands therefore remain public lands
and form part of the public domain. Citing the case of Chavez v Public Estates, the
Court stated that foreshore and submerged areas are irrefutably part of the public
domain, and are inalienable unless reclaimed, classified as alienable lands open to
disposition and further declared no longer needed for public service. The fact that The
fact that alienable lands of the public domain were transferred to the PEA (now PRA)
and issued land patents or certificates of title in PEA's name did not automatically
make such lands private. This Court also held therein that reclaimed lands retained
their inherent potential as areas for public use or public service.
Reclaimed lands such as the subject lands in issue are reserved lands for public use.
They are properties of public dominion. The ownership of such lands remains with the
State unless they are withdrawn by law or presidential proclamation from public use.