Republic of the Philippines v City of Paranaque 2.

On October 26, 2004, then President GMA issued EO 380, which transformed
GR No. | Date | Topic (what we need to focus on) | Ponente | Your Surname PEA into PRA, which was granted the authority to exercise all the powers and
functions of the PEA relating to reclamation activities.
Petitioner: Republic of the Philippines, represented by the Philippine Reclamation
3. By virtue of its mandate, PRA reclaimed several portions of the foreshore
Authority
and offshore areas of Manila Bay, including those located in Paranaque City.
Respondents: City of Paranaque
The Paranaque City Treasurer issued warrants of levy on PRA’s reclaimed
properties based on the assessment for delinquent real property tax for the
Recit-Ready: The Public Estates Authority was created by PD 1084, and
years 2001 and 2002.
transformed by EO 380 into the PRA. It is granted the authority to exercise all the
4. PRA however, claims that reclaimed lands are still part of the public domain,
powers and functions of the PEA relating to reclamation activities. The PRA
owned by the state, and therefore exempt from payment of real estate taxes.
reclaimed several portions of land in the foreshore and offshore areas of Manila
Bay. The Treasurer of the City of Paranaque assessed the PRA real estate tax
ISSUE/S:
deficiency for the years 2001 and 2002. The PRA however, contends that reclaimed
lands are part of the public domain, and are thus exempt from real estate tax. The W/N reclaimed lands are part of the public domain, and are thus exempt from real
issue is whether or not reclaimed lands form part of the public domain. The Court estate tax – YES.
here held in the 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 RATIO:
v Public Estates, the Court stated that foreshore and submerged areas are
irrefutably part of the public domain, and are inalienable unless reclaimed, Issue 1: Article 420 of the Civil Code enumerates properties belonging to the State:
classified as alienable lands open to disposition and further declared no longer
needed for public service. Reclaimed lands such as the subject lands in issue are Art. 420. The following things are property of public dominion:
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ownership of such lands remains with the State unless they are withdrawn by law or (1) Those intended for public use, such as roads, canals, rivers,
presidential proclamation from public use. torrents, ports and bridges constructed by the State, banks, shores,
roadsteads, and others of similar character;
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 (2) Those which belong to the State, without being for public use, and
remains with the State unless they are withdrawn by law or presidential are intended for some public service or for the development of the
proclamation from public use. national wealth.

Here, the lands subject of litigation are reclaimed lands, specifically portions of the
FACTS:
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,
1. The Public Estates Authority is a government corporation created by virtue
the Court stated that foreshore and submerged areas are irrefutably part of the public
of PD 1084 to provide a coordinated, economical and efficient reclamation
domain, and are inalienable unless reclaimed, classified as alienable lands open to
of lands, and the administration and operation of lands belonging to,
disposition and further declared no longer needed for public service. The fact that The
managed and/or operated by the government with the object of maximizing
fact that alienable lands of the public domain were transferred to the PEA (now PRA)
their utilization and hastening their development consistent with public
and issued land patents or certificates of title in PEA's name did not automatically
interest.
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.