Municipality of Pateros v. City of Taguig
REITERATIONFacts
The Antecedents: The Municipality of Pateros (Pateros) filed a petition for review on certiorari seeking to reverse the Court of Appeals' (CA) dismissal of its appeal. The CA had affirmed the Regional Trial Court's (RTC) dismissal of Pateros' complaint for judicial declaration of territorial boundaries. The dispute stemmed from a long-standing boundary disagreement involving portions of Fort William McKinley (now Fort Bonifacio) among Pateros, the City of Taguig (Taguig), and the City of Makati (Makati). Taguig and Makati had been embroiled in litigation for 30 years over these areas, with Presidential Proclamations declaring them part of Makati. Procedural History: Pateros had previously filed a case (Civil Case No. 93-4529) seeking judicial declaration of its territorial boundaries and nullification of presidential proclamations, which was dismissed by the RTC for lack of jurisdiction. Taguig had also filed a case (Civil Case No. 63896) against Makati and government agencies, seeking confirmation of its territory and declaration of unconstitutionality of certain presidential proclamations. The RTC ruled in favor of Taguig, but this decision was later reversed by the CA, which held that the proclamations merely confirmed Makati's territory. This led to further litigation and contempt charges against Makati's counsels. In a separate case (G.R. No. 157714), the Supreme Court denied Pateros' petition but directed Pateros and Makati to comply with Section 118 of the Local Government Code (LGC) for amicable settlement by referring the dispute to their respective sanggunians. Pateros attempted to initiate dialogues, but due to the ongoing dispute between Makati and Taguig, an amicable settlement could not be reached. Pateros then filed the present case (Civil Case No. 73387-TG) before the RTC Pasig, Branch 271, seeking judicial declaration that Parcel 4 of Survey Plan Psu-2031 is within Pateros' territorial jurisdiction. The RTC dismissed the case for lack of jurisdiction, finding that Pateros failed to comply with the LGC's procedural requirements for boundary disputes. The CA affirmed the RTC's dismissal. The Petition: Pateros assailed the CA's ruling, arguing that it had substantially complied with the LGC provisions and that the respondents' uncooperative stance made further compliance impossible. Pateros contended that the CA erred in ruling that the RTC lacked jurisdiction and that it was denied its right to equal protection.
Issue(s)
Whether Pateros complied with the requirements of Sections 118(d) and (e) of the Local Government Code (LGC) and Rule III of its Implementing Rules and Regulations (IRR), as directed by the Supreme Court in G.R. No. 157714. Whether the failure of the Taguig Sanggunian to respond to resolutions seeking settlement of the boundary dispute through council-to-council dialogue justified the filing of Civil Case No. 73387-TG against both Taguig and Makati. Whether the Regional Trial Court (RTC) Pasig, Branch 271, has jurisdiction over the subject matter of Civil Case No. 73387-TG.
Ruling
The petition is GRANTED. The January 29, 2015 Decision and September 24, 2015 Resolution of the Court of Appeals in CA-G.R. CV No. 101512 are REVERSED and SET ASIDE. The Regional Trial Court of Pasig City, Branch 271, Taguig City Station, is DIRECTED to REINSTATE Civil Case No. 73387-TG and proceed with dispatch.
Ratio Decidendi
On the compliance with Sections 118(d) and (e) of the LGC and Rule III of the IRR: The Court found that Pateros had substantially complied with the requirements. While the LGC mandates amicable settlement through respective sanggunians, Pateros took steps to initiate dialogues with Makati and Taguig. Makati initially participated, but an amicable settlement between Pateros and Makati was deemed impossible due to the ongoing dispute between Makati and Taguig. Taguig's lack of response to Pateros' invitations for dialogue was interpreted as a refusal to amicably settle. The Court reiterated that the procedure requires a joint referral and joint exercise of jurisdiction by the sanggunians, which was made impossible by Taguig's inaction. On whether Taguig's failure to respond justified the filing of the case: The Court ruled that Taguig's silence and inaction, akin to a refusal to submit the case for settlement, effectively resulted in the failure of amicable settlement under Section 118(e) of the LGC. This situation, similar to the one in Province of Antique v. Judge Calabocal, justified Pateros in pursuing judicial recourse. The Court emphasized that a party cannot insist on strict adherence to a procedure that it itself has made impossible to follow. On the jurisdiction of the RTC Pasig, Branch 271: The Court held that the RTC has jurisdiction over the dispute. It clarified that while the LGC vests original jurisdiction over boundary disputes between LGUs in their respective sanggunians, resort to the RTC is permitted upon failure of the amicable settlement process. The Court found that Pateros' filing of Civil Case No. 73387-TG should be treated as an original action, not an appeal under Section 119 of the LGC, because there was no decision rendered by the sanggunians. The Court's directive in G.R. No. 157714 to follow the LGC procedure was "without prejudice to judicial recourse," which Pateros availed of due to the respondents' uncooperative stance. The Court reinstated the case, directing the RTC to proceed with dispatch.
Main Doctrine
The Supreme Court held that while the Local Government Code (LGC) mandates an amicable settlement of boundary disputes between Local Government Units (LGUs) through their respective sanggunians, resort to judicial recourse is warranted when one LGU's uncooperative stance makes compliance with the prescribed procedure impossible. The Court affirmed that the Regional Trial Court (RTC) has jurisdiction over such disputes when the administrative remedies are rendered futile by the parties' actions or inactions.