DUMAGUETE CITY — A March 26, 2026 letter from the National Commission for Culture and the Arts addressed to Dumaguete City Mayor Manuel T. Sagarbarria has raised fresh accountability questions for the Sangguniang Panlungsod and the City Development Council, with concerned parties now asking whether the same heritage, archaeological, and environmental safeguards outlined in that letter should be applied before the city proceeds with its proposed new public market and City Hall extension projects.
The NCCA letter, which was originally issued in connection with a proposed convention center to be built in front of the St. Catherine of Alexandria Cathedral near the Campanario de Dumaguete, outlined a set of mandatory documentary requirements that must be satisfied before any construction activity could commence on the site. The central question now being raised is whether city officials formally disclosed the contents of this letter to the Council and the CDC before deliberations on the market and City Hall projects moved forward.
NCCA Letter Cited Campanario's Protected Status and Dumaguete's Archaeological Classification
According to the March 26, 2026 letter, the Campanario de Dumaguete holds the status of a declared Important Cultural Property and a Grade II Cultural Property under Philippine heritage law. The NCCA noted that a protected buffer zone extends five meters from the visible perimeter of the Campanario, meaning any construction activity in its immediate vicinity is subject to strict cultural and heritage compliance requirements.
The letter further stated that Dumaguete City itself is formally identified as an archaeological site and is recognized as an Environmentally Critical Area, a classification grounded in the city's unique historic, archaeological, and scientific significance. These designations are not administrative formalities — they carry legal weight and impose specific obligations on project proponents, whether private or government.
While the NCCA's letter was specifically addressed to the proposed convention center project, heritage advocates and civic observers have pointed out that the basis for those requirements — proximity to a declared cultural property, location within an archaeological zone, and the city's status as an Environmentally Critical Area — would logically apply to any major infrastructure project in the same historic core of the city.
Republic Act 10066 Mandates Heritage Reviews in Infrastructure Projects
Under Republic Act No. 10066, also known as the National Cultural Heritage Act of 2009, any government or non-government infrastructure project or architectural site development is required to incorporate anthropological, archaeological, historical, and heritage site conservation concerns into the Environmental Impact Assessment System. The law, as cited in the Supreme Court E-Library, also grants cultural agencies the authority to inspect important cultural properties and national historical landmarks to ensure their protection and integrity.
This legal framework means that the public market and City Hall extension projects — both of which are expected to rise in an area of the city considered heritage-sensitive — may be subject to the same documentary and compliance requirements outlined in the NCCA's March 26 letter to Mayor Sagarbarria.
The documents the NCCA required for the convention center project included an Archaeological Impact Assessment, a Heritage Impact Assessment, an As-Built or As-Found Plan, detailed development plans, scope of works, construction methodology documentation, and photo documentation of the current site condition. These are the baseline requirements that must be submitted before any ground-disturbing activity can legally proceed on a site within or adjacent to a declared cultural property.
Council and CDC Asked Whether NCCA Letter Was Formally Disclosed Before Deliberations
The accountability question now being raised is direct: were the members of the Sangguniang Panlungsod and the City Development Council formally furnished a copy of the NCCA's March 26, 2026 letter before the first reading or endorsement of the market and City Hall projects took place?
If the Council and CDC were not informed of the NCCA letter prior to their deliberations, the matter constitutes a gap in transparency that warrants disclosure. If they were informed, concerned parties and the general public are entitled to know what specific steps were taken in response to ensure that the proposed projects are in compliance with applicable heritage laws and NCCA guidelines.
Concerned observers have suggested that the Sangguniang Panlungsod may require the Executive Department to submit a written certification or formal guarantee confirming that the proposed public market and City Hall extension projects have already secured — or will secure prior to implementation — the necessary NCCA opinion, heritage clearance, archaeological assessment, environmental compliance documents, and all other approvals from relevant cultural agencies.
Heritage Proximity, Not Project Name, Drives NCCA's Compliance Standards
A critical point raised in the ongoing discussion is that the NCCA's requirements for the convention center were not triggered by the nature or name of the project itself. They were triggered by the project's location — its proximity to a declared heritage structure, its position within an archaeologically sensitive zone, and its potential impact on the historic core of Dumaguete City.
This distinction matters for the public market and City Hall extension projects. If those projects are located in the same or similarly sensitive heritage area — which available information suggests they are — then the threshold for NCCA compliance is met regardless of whether the word "convention center" appears in the project title.
The NCCA's mandate under RA 10066 is to safeguard the physical integrity of declared cultural properties and the archaeological landscape of areas classified as heritage zones. Dumaguete City's classification as both an archaeological site and an Environmentally Critical Area is a standing designation, not a case-by-case determination, meaning all major construction projects within that zone are theoretically subject to the same scrutiny.
Transparency and Due Process Raised as Parallel Concerns
Beyond the legal compliance dimension, the issue has also surfaced questions about transparency and due process in how the city's development projects have been presented to the public and to the legislative body responsible for approving them.
The Sangguniang Panlungsod, as the legislative arm of the city government, has the authority and the responsibility to require the Executive Department to produce documentation showing that major public infrastructure projects comply with all applicable laws — including heritage and cultural property laws — before those projects receive final legislative endorsement or funding appropriation.
Civic observers have noted that Dumaguete regularly promotes itself as a historic, cultural, and heritage city. That identity carries a corresponding obligation to ensure that publicly funded development projects in the historic center undergo the same level of scrutiny applied to any privately funded construction in similar zones.
No Confirmation Yet From City Hall on NCCA Compliance Status
As of the time of publication on June 7, 2026, no official statement has been issued by the Office of Mayor Manuel T. Sagarbarria, the Sangguniang Panlungsod, or the City Development Council addressing whether the March 26, 2026 NCCA letter was formally disclosed to legislative and planning bodies prior to deliberations on the public market and City Hall extension projects.
No public documentation has been made available confirming that an Archaeological Impact Assessment, Heritage Impact Assessment, or any of the other documents required under RA 10066 and the NCCA's own guidelines have been commissioned or submitted for either project.
The Sangguniang Panlungsod is expected to continue deliberations on the city's proposed infrastructure projects in the coming weeks. Heritage advocates and civic watchdogs have indicated that they will be monitoring whether the disclosure and compliance questions raised by the NCCA letter are formally addressed before any project in the historic core receives final legislative or executive approval.
The public market and City Hall extension projects represent significant public investments intended to serve the residents of Dumaguete City. At issue is not whether those facilities should be built, but whether the process leading to their construction meets the legal, environmental, and cultural compliance standards that Philippine law requires for development in a city formally recognized as an archaeological site and an Environmentally Critical Area.
Photo credit: Photo courtesy of Kenneth / Breaking News Negros Oriental