Province of Camarines Sur v. Honorable Court of Appeals;

Summary

This case involves a territorial jurisdiction dispute between Province of Camarines Sur and City of Naga over administrative control of Plaza Rizal, a public plaza. The Province claimed ownership through continuous possession and tax declarations, while the City claimed administrative control based on the plaza being within its territorial boundaries. The legal issue centered on interpreting Republic Act No. 305 (City of Naga Charter) and determining which local government unit should control public property within city limits. The Supreme Court ultimately ruled that Plaza Rizal, being property for public use located within City of Naga's territorial jurisdiction, should be under the city's administrative control and supervision. The Court applied the principle that when a municipality becomes a city, administrative control of public properties within the new city's territory transfers to the city government. The case also addressed procedural issues regarding the distinction between Rule 45 (petition for review) and Rule 65 (certiorari) remedies.