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CENTRAL MINDANAO UNIVERSITY v. EXECUTIVE SECRETARY

FACTS:

Central Mindanao University (CMU) is a state-owned educational institution. In 1958, Presidential Proclamation 476 reserved 3,401 hectares of lands for CMU's school site. CMU obtained title over 3,080 hectares of those lands, while the remaining untitled lands were distributed to cultural communities in the area.

In 2003, President Gloria Macapagal-Arroyo issued Presidential Proclamation 310, which took 670 hectares from CMU's registered lands for distribution to indigenous peoples and cultural communities. CMU filed a petition for prohibition seeking to stop the implementation of Presidential Proclamation 310 and have it declared unconstitutional.

The National Commission on Indigenous Peoples (NCIP) moved to dismiss the case, arguing that the trial court lacked jurisdiction over an executive act. The trial court denied the motion and proceeded with CMU's application for preliminary injunction. After hearing the preliminary injunction incident, the trial court granted the NCIP's motion for partial reconsideration and dismissed CMU's action for lack of jurisdiction, although it ruled that Presidential Proclamation 310 was constitutional. CMU filed a motion for reconsideration, but it was denied. CMU then appealed to the Court of Appeals (CA).

In its appeal, CMU questioned whether the trial court deprived it of due process and argued about the constitutionality of Presidential Proclamation 310. However, the CA dismissed CMU's appeal for lack of jurisdiction, stating that CMU should have filed a petition for review directly with the Supreme Court. CMU's motion for reconsideration was also denied, prompting them to file a petition for review.

ISSUES:

  1. Whether or not the CA erred in not finding that the RTC erred in dismissing CMU's action for prohibition against NCIP, et al for lack of jurisdiction and at the same time ruling that Presidential Proclamation 310 is valid and constitutional.

  2. Whether or not the CA correctly dismissed CMU's appeal on the ground that it raised purely questions of law that are proper for a petition for review filed directly with this Court.

RULING:

  1. The Court held that the CA did not err in its findings. The RTC correctly dismissed CMU's action for lack of jurisdiction because the act sought to be enjoined, which is the issuance of Presidential Proclamation 310, is an official act of the Executive Department done in Manila. Therefore, jurisdiction lies with the Manila RTC. However, the RTC ruled that Presidential Proclamation 310 is valid and constitutional based on the ultimate ownership of the lands by the State and CMU's mere holding of the same in its behalf.

  2. The Court agreed with the CA's decision to dismiss CMU's appeal. The issues raised by CMU mainly pertain to the constitutionality of Presidential Proclamation 310, which are pure questions of law. Therefore, the proper recourse should have been a petition for review on certiorari filed directly with the Court.

PRINCIPLES:

  • A court must have jurisdiction over a case and the subject matter before it can proceed with the proceedings.

  • Pure questions of law, which involve the application or interpretation of law, are proper for a petition for review filed directly with the Court.

  • Compliance with procedural requirements is necessary for the proper filing of a petition.