• This case resolves the issue of whether open spaces and road lots in a private subdivision automatically become public property by virtue of local ordinances requiring their turnover. A concerned citizen filed a case after the Quezon City government spent public funds on improving such areas, which were still titled under a private name. The Supreme Court affirmed the Court of Appeals, holding that the transfer of these spaces is not automatic. A positive act, such as a formal deed of donation and acceptance, is required. Without proof of such a transfer, the properties remain private, and the propriety of spending public funds on them is questionable.

• The Complainant: Rainier Madrid, a taxpayer and resident of Quezon City, questioned the local government's expenditure of public funds for the improvement of roads and open spaces within Capitol Park Homes Subdivision (CPHS).
• The Property in Question: The road lots and open spaces, including one where a public parish stands, were found to be titled under a private corporation's name, not the Quezon City government.
• The Ordinances: A series of Quezon City ordinances required subdivision developers like VV Soliven, the developer of CPHS, to turn over 6% of their open spaces to the city government as a condition for the approval of their subdivision plan.
• The Lawsuit: After a plunder complaint was dismissed by the Ombudsman pending a determination of the properties' nature, Madrid filed a Petition for Declaratory Relief to clarify the effect of the ordinances and determine if the properties were public or private.

• RTC Ruling: The RTC dismissed the petition, finding that the developer had already breached the ordinance (by not donating the land), making declaratory relief improper. It also ruled that Madrid was not a real party-in-interest.
• Court of Appeals (CA) Ruling: The CA reversed the RTC. It held that declaratory relief was a proper remedy and that Madrid, as a taxpayer, had legal standing. The CA then declared the properties to be private in nature because the QC government failed to present any proof of a formal donation.

• Was the Petition for Declaratory Relief a proper remedy?
• Do subdivision open spaces and road lots automatically become public property upon the approval of a subdivision plan under a local ordinance, or is a separate act of donation required?

The Supreme Court DENIED the Quezon City government's petition and AFFIRMED the CA's finding.

• Declaratory Relief was Proper: The Court found that although the RTC initially erred, the CA was correct in entertaining the petition. The ultimate goal was to determine the propriety of public spending, which required a declaration of the properties' nature.
• No Automatic Transfer of Ownership: The Court affirmed the doctrine in *Republic v. Sps. Llamas*. The turnover of subdivision road lots and open spaces to the government is NOT automatic. An ordinance cannot compel a donation, as this would be an illegal taking. A positive act—such as a duly executed and accepted Deed of Donation—is required.
• Burden of Proof on the Government: Since the QC government asserted ownership to justify its spending, it had the burden to prove a valid transfer. It failed to present any deed of donation or other proof of acquisition. Therefore, the properties remained private.

• Donation of Subdivision Open Spaces: The transfer of ownership of open spaces and road lots from a subdivision developer to a local government is not automatic and cannot be compelled by ordinance. A positive act of conveyance, like an accepted donation, is necessary.
• Illegal Taking: Forcing a developer to donate property without compensation constitutes an illegal taking and is an invalid exercise of police power.
• Taxpayer's Standing: A taxpayer has legal standing to file a suit to question the illegal disbursement of public funds, such as spending on private property.
• Declaratory Relief: This remedy is appropriate to determine rights under a statute or ordinance before a breach has occurred, especially when prompted by another government body (like the Ombudsman) to seek judicial clarification.