SP of Bataan Vs

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SP of Bataan vs. Cong.

Garcia,
G.R. No. 174964,
Oct. 5, 2016

FACTS:

The Bataan Community Colleges and the Medina Lacson de Leon School of Arts and Trades occupied
various parcels of land registered under the Province of Bataan. When Congress passed RA. 8562,
authored by Cong. Garcia, it converted the MLLSAT into a polytechnic college which integrated the BCC.
Garcia then requested the lots to be transferred to the BPSC, however, the SP of Bataan insisted that it
could not be transferred as the properties were not communal but patrimonial properties of the Province
of Bataan.

ISSUE: Whether or not R.A. No. 8562 infringes on the State's underlying policy of local
autonomy for its territorial and political subdivisions?

RULING: : No. The Philippine concept of local autonomy only delegates administrative powers to their
political subdivisions, and does not deal with issues concerning ownership and classification or use of
properties held by the local governments. The State still retains power over property of the public domain,
exercised through Congress. Therefore, R.A. No. 8562 does not infringe on the State’s underlying policy
of local autonomy as there is no dispute that the Congress has expressly intended to entrust to BPSC the
titles to the subject lots.

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