Municipality of Kananga v. Madrona
NEW DOCTRINEFacts
The Antecedents: A boundary dispute arose between the Municipality of Kananga and the City of Ormoc. The parties attempted an amicable settlement through a joint session of their respective sanggunians on October 31, 1997. No settlement was reached, and Resolution No. 97-01 was issued, certifying the failure to settle amicably and agreeing to elevate the matter to the proper court. Procedural History: The City of Ormoc filed a Complaint before the Regional Trial Court (RTC) of Ormoc City (Branch 35) on September 2, 1999, to settle the boundary dispute. The Municipality of Kananga filed a Motion to Dismiss, arguing that the RTC had no jurisdiction over the subject matter, there was no cause of action, and a condition precedent was not complied with. The RTC denied the Motion to Dismiss in an Order dated October 29, 1999, holding that it had jurisdiction under Batas Pambansa Blg. 129 and that Section 118 of the Local Government Code had been substantially complied with, with parties agreeing to elevate the matter to court. The Petition: The Municipality of Kananga filed a Petition for Certiorari under Rule 65 of the Rules of Court, seeking to annul the RTC's Order denying its Motion to Dismiss.
Issue(s)
Whether the Regional Trial Court (RTC) may exercise original jurisdiction over the settlement of a boundary dispute between a municipality and an independent component city.
Ruling
The Petition has no merit. The challenged Order of the RTC is affirmed.
Ratio Decidendi
On the issue of whether the Regional Trial Court (RTC) may exercise original jurisdiction over the settlement of a boundary dispute between a municipality and an independent component city: The Supreme Court ruled in the affirmative, holding that the RTC does possess original jurisdiction over such disputes. The Court first clarified that jurisdiction is vested by law and cannot be conferred or waived by the parties, serving as a fundamental principle in judicial process. It then examined Section 118 of the 1991 Local Government Code (LGC), which outlines the jurisdictional responsibility for the settlement of boundary disputes among local government units. The Court meticulously analyzed the classifications in Section 118, noting that while Kananga is a municipality, Ormoc is an independent component city, not a highly urbanized city. Specifically, Section 118(d) addresses disputes involving a component city or municipality on one hand and a highly urbanized city on the other, or two or more highly urbanized cities. Since Ormoc is an independent component city and not a highly urbanized city, the Court concluded that the procedure outlined in Section 118 does not apply to a boundary dispute between a municipality and an independent component city. Consequently, the general rules governing jurisdiction must be applied. The applicable provision is Section 19(6) of Batas Pambansa Blg. 129, otherwise known as the Judiciary Reorganization Act of 1980, as amended by Republic Act No. 7691, which grants Regional Trial Courts exclusive original jurisdiction in "all cases not within the exclusive jurisdiction of any court, tribunal, person or body exercising judicial or quasi-judicial functions." Since there is no specific law providing for the exclusive jurisdiction of any court or agency over the settlement of boundary disputes between a municipality and an independent component city, the RTC, as a court of general jurisdiction, properly exercised its authority.
Main Doctrine
Regional Trial Courts have original jurisdiction over boundary disputes between a municipality and an independent component city, in the absence of a specific statutory provision granting exclusive jurisdiction to another body.