Barangay Mayamot v. Antipolo
REITERATIONFacts
The Antecedents: In 1984, Batas Pambansa Blg. 787 to 794 were enacted, creating eight new barangays in Antipolo and defining their territories. This expanded Antipolo to sixteen barangays. Subsequently, the Sangguniang Bayan of Antipolo passed Resolution No. 97-80, commissioning the City Assessor to delineate the territorial boundaries of these sixteen barangays based on Cadastral Survey No. 29-047 and the aforementioned Batas Pambansa. This led to the passage of Resolution No. 97-89, which formally approved the barangay boundaries as prepared and plotted by the Assessor's Office. Procedural History: Barangay Mayamot filed a Petition for Declaration of Nullity and/or Annulment of Resolution No. 97-89 and Injunction before the Regional Trial Court (RTC) of Antipolo City, alleging that the resolution reduced its territory without legal basis and proper procedure. The RTC dismissed the petition, holding that Resolution No. 97-89 was not intended to alter territorial boundaries and that the issue was a boundary dispute. Barangay Mayamot appealed to the Court of Appeals (CA), which affirmed the RTC's decision, ruling that the RTC lacked jurisdiction over boundary disputes and that the Local Government Code of 1991 provided the proper mechanism for their settlement. The CA denied Barangay Mayamot's motion for reconsideration. The Petition: Barangay Mayamot filed a Petition for Review on Certiorari under Rule 45 of the Revised Rules of Court, assailing the CA's decision. The petitioner reiterates its argument that Resolution No. 97-89 altered its territory without legal basis and in violation of Section 82 of the Local Government Code of 1983, which requires an ordinance and a plebiscite for boundary alterations. The respondents, in their comment, maintain that the case is a boundary dispute and that the lower courts correctly dismissed it for lack of jurisdiction.
Issue(s)
Whether the Regional Trial Court (RTC) has original jurisdiction over the petition filed by Barangay Mayamot regarding a boundary dispute. Whether Resolution No. 97-89 of the Sangguniang Bayan of Antipolo City is null and void for allegedly altering the territorial boundary of Barangay Mayamot without the required ordinance and plebiscite, and whether this is fundamentally a boundary dispute.
Ruling
The petition is denied for lack of merit. The Decision dated January 30, 2009 and Resolution dated March 31, 2009 of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court held that the nature of an action and its subject matter, which determines jurisdiction, are based on the material allegations of the complaint in relation to the law and the character of the reliefs prayed for. In this case, despite being captioned as a petition for nullity of Resolution No. 97-89, the allegations of Barangay Mayamot centered on the inconsistency between its perceived actual territory and its territory as defined after the consolidation and integration of boundaries. This clearly constituted a boundary dispute between Barangay Mayamot and Barangays Bagong Nayon, Sta. Cruz, Cupang, and Mambugan. The Court emphasized that jurisdiction is determined by the statute in force at the time of the commencement of the action. Since Republic Act No. 7160 (Local Government Code of 1991) was in effect when the petition was filed, its provisions on boundary disputes apply. Section 118 of RA No. 7160 explicitly states that boundary disputes between and among local government units shall be referred for settlement to the sangguniang panlungsod or sangguniang bayan concerned. The RTC loses its power to try such cases at the first instance, only acquiring appellate jurisdiction after the administrative body has rendered a decision. Therefore, the RTC correctly dismissed the case for lack of original jurisdiction. On the alleged nullity of Resolution No. 97-89: The Court found that the issue raised by Barangay Mayamot was fundamentally a boundary dispute, not a question of the validity of the resolution itself in terms of its enactment process. The RTC and the Court of Appeals both found that Resolution No. 97-89 was passed in consequence of BP Blg. 787 to 794 and was based on the Bureau of Lands Cadastral Survey No. 29-047, and was not intended to alter the territorial boundary of Barangay Mayamot. The Court reiterated that any discrepancy between the cadastral survey and the physical boundary is a matter of boundary dispute. Since the RTC lacked original jurisdiction over boundary disputes, it could not pass upon the merits of whether Resolution No. 97-89 altered Barangay Mayamot's territory or if it complied with the requirements of Section 82 of BP Blg. 337. The proper venue for such determination, after the administrative process, would be the RTC on appeal.
Main Doctrine
The Regional Trial Court (RTC) has no original jurisdiction to hear and decide boundary disputes between barangays within the same city or municipality; such disputes are initially cognizable by the Sangguniang Panlungsod or Sangguniang Bayan, with the RTC exercising appellate jurisdiction only after the administrative body has decided the dispute.