Municipality of Isabel v. Municipality of Merida
REITERATIONFacts
The Antecedents: The Municipality of Isabel was created from eight barrios of the Municipality of Merida pursuant to Republic Act (R.A.) No. 191, enacted on June 22, 1947, and formalized by Presidential Proclamation No. 49 on January 15, 1948. Boundary monuments were placed to mark the boundary line. A dispute arose concerning two monuments placed along a dead creek named Doldol. Merida claimed that when Isabel installed new boundary monuments in 1981, a new monument (MBM No. 5) was placed along the Benabaye River, altering the boundary and creating a disputed area of 162.3603 hectares. Structures were erected and jurisdiction was exercised by Isabel within this disputed area, prompting Merida to initiate action. Procedural History: The Sangguniang Panlalawigan of Leyte adjudicated the boundary dispute in favor of Merida, ordering Isabel to remove MBM No. 5 and directing Merida to install a new monument along Doldol Creek. The Regional Trial Court (RTC) reversed the Sangguniang Panlalawigan's decision, ruling in favor of Isabel and declaring the disputed area as belonging to Isabel, giving weight to testimonies of old residents and an ocular inspection. Merida's motion for new trial was denied. The Court of Appeals (CA) reversed the RTC decision, reinstating the Sangguniang Panlalawigan's resolution, giving more weight to the 1947 stone monument near the Doldol tree. The Petition: Isabel filed a Petition for Review on Certiorari with the Supreme Court, arguing that the CA erred in reinstating the Sangguniang Panlalawigan resolution because the existence of the monument near the Doldol tree was unproven, and the preponderance of evidence favored MBM No. 5 as the true boundary.
Issue(s)
Whether the Court of Appeals erred in reinstating the Sangguniang Panlalawigan resolution in favor of Merida. Whether the existence of the monument near the ancient doldol tree was proven. Whether the preponderance of evidence shows that the disputed portion is part of Barangay Apale, demarcated by MBM No. 5.
Ruling
The petition is denied. The Court of Appeals did not err in reinstating the adjudication of the boundary dispute by the Sangguniang Panlalawigan of Leyte, affirming that the true boundary line is marked by the old shoreward monument and the monument along the old Doldol Creek near the ancient doldol tree.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in reinstating the Sangguniang Panlalawigan resolution: The Supreme Court held that the CA did not err. The Court reiterated that the Constitution and the Local Government Code mandate that substantial alterations in LGU boundaries require a law enacted by Congress and approval by a majority vote in a plebiscite. In boundary disputes, the function of tribunals is limited to the factual determination of the correct boundary line in accordance with the statutes creating the LGUs involved. The Court found that the Sangguniang Panlalawigan's adjudication, which was reinstated by the CA, was more congruent with R.A. No. 191, the law creating Isabel. The Court emphasized the importance of precise boundary delineation for the legitimate exercise of governmental powers. On the issue of the proof of the monument near the ancient doldol tree: The Court found sufficient evidence to establish the existence of the doldol monument. While it was not seen during the RTC's ocular inspection, Merida presented photographic and testimonial evidence, including the testimony of Isabel's first mayor, Galicano Ruiz, which sufficiently established its location and installation. The Court considered this monument, along with the lost shoreward monument, as marking the true boundary. The Court noted that even if the monument was lost, it could be considered obliterated, but Merida was able to present evidence for its recovery, making it more than just hearsay. On the issue of whether the preponderance of evidence favors MBM No. 5: The CA correctly disregarded Isabel's MBM No. 5. The Court found that MBM No. 5 was based on surveying regulations not contemporaneous with the foundation of Isabel in 1947. The Court gave greater weight to the 1947 stone monument, which was installed during Isabel's creation and still exists, as supported by Mayor Ruiz's testimony and other evidence. The Court also found that tax declarations indicating properties within the disputed area as "Benabaye, Isabel, Leyte" were misleading, as Benabaye is a barangay of Merida. Furthermore, the residency of barangay officials of Benabaye within the disputed area bolstered Merida's claim, as the Local Government Code requires officials to be residents of the LGU they serve. The Court concluded that R.A. No. 191 did not include Benabaye in the enumeration of barrios that comprise Isabel, implying a deliberate exclusion.
Main Doctrine
In adjudicating local government unit boundary disputes, tribunals are limited to the factual determination of the correct boundary line in accordance with the statutes creating the LGUs involved, giving primacy to the legislative intent as expressed in the municipal charters.