Republic of the Philippines v City of Paranaque GR No.

191109
Picot, Praisah Marjorey F.

FACTS:

By virtue of EO 380, PRA was then designated as the agency primarily responsible for directing,
integrating and coordinating all reclamation projects in behalf of the national government. By virtue of
its mandate PRA reclaimed several portions of the foreshore and offshore areas of the Manila Bay
including those located in Paranaque City. OCTs and TCTs over the reclaimed lands were issued in its
name.
Meanwhile, City of Paranaque contends that PRA is a GOCC and thus it should pay real property taxes.
On the other hand PRA argued that it is not a GOCC and despite the fact that the said areas were
reclaimed; they are still considered property of the public domain hence free from taxes.

ISSUE:

Whether or not the reclaimed lands are still part of the public domain?

RULING:

Yes. The mere reclamation of these areas by PRA does not convert these inalienable natural resources
of the State into alienable or disposable lands of the public domain.
There must be a law or presidential proclamation officially classifying these reclaimed lands as alienable
or disposable and open to disposition or concession.

Therefore, the reclaimed lands are property of public dominion and all the characteristics of property of
the public dominion apply to them.