G.R. No. 187349 - Barangay Mayamot, Antipolo City vs. Antipolo City

In 1984, Batas Pambansa Nos. 787 to 794 were enacted, creating eight new barangays in the then Municipality of Antipolo.
The laws included provisions regarding the sitios comprising each barangay, their boundaries, and the mechanism for ratification.
With the addition of the new barangays (Beverly Hills, Dalig, Bagong Nayon, San Juan, Sta. Cruz, Munting Dilaw, San Luis, and Inarawan) to the previously existing eight (Calawis, Cupang, Mambugan, Dela Paz, San Jose, San Roque, San Isidro, and Mayamot), Antipolo became composed of sixteen barangays.

To incorporate the territorial jurisdictions of the sixteen barangays into the city map of Antipolo, the Sangguniang Bayan passed Resolution No. 97-80, commissioning the City Assessor to plot and delineate these boundaries in accordance with Bureau of Lands Cadastral Survey No. 29-047 and the provisions of BP Blg. 787 to 794.
On October 25, 1989, the Sangguniang Bayan adopted Resolution No. 97-89, which defined the territorial boundaries of both the newly created barangays and the formerly existing ones by approving the plans and maps prepared by the City Assessor.
The resolution emphasized the reliance on the cadastral survey and the law creating the barangays while stressing the need to avoid administrative conflicts and territorial encroachments.
The text of the resolution included multiple “whereas” clauses showing the basis of the boundaries and was purportedly enacted without alteration of the original territorial boundaries.

On September 21, 1999, Barangay Mayamot filed a petition before the Regional Trial Court (RTC) of Antipolo City seeking the declaration of nullity and/or annulment of Resolution No. 97-89 along with an injunction.
The petition alleged that Resolution No. 97-89 reduced Barangay Mayamot’s territory by effectively apportioning a portion of its area to Barangays Sta. Cruz, Bagong Nayon, Cupang, and Mambugan.
It further claimed that the City Assessor’s preparation of the map and the subsequent approval of Resolution No. 97-89 were made without any consultation or public hearing.
Barangay Mayamot asserted that the resolution violated Section 82 of BP Blg. 337 (Local Government Code of 1983), which required that any alteration or modification of barangay boundaries be enacted by ordinance and ratified by a plebiscite.

The RTC rendered its decision on August 1, 2006, dismissing the petition based on the finding that Resolution No. 97-89 was enacted pursuant to the Cadastral Survey Plan and did not intend to alter Barangay Mayamot’s boundaries.
The RTC noted that the dispute raised was essentially a boundary dispute, which under the prevailing law (Local Government Code of 1983 at that time) should be settled through appropriate mechanisms rather than via the petition filed.
Barangay Mayamot filed its Notice of Appeal on August 29, 2006.
The Court of Appeals, in its decision dated January 30, 2009, denied the appeal by affirming that the case was purely a boundary dispute, and highlighted that the creation of the additional barangays was validly executed with the requisite plebiscite (as per Commission on Elections Resolution No. 96-2551).
Subsequently, a Motion for Reconsideration filed on February 17, 2009, was denied by the Court of Appeals in its Resolution dated March 31, 2009.

At the time of the filing, RA No. 7160 or the Local Government Code of 1991 was in force.
Sections 118 and 119 of RA No. 7160 provided the proper mechanism for settling boundary disputes, specifically by vesting original jurisdiction in the Sangguniang Panglungsod or Sangguniang Bayan, and only subsequently allowing an appeal to the RTC if the sanggunian’s decision is contested.

Whether the RTC had original jurisdiction to decide a petition for declaration of nullity/annulment which essentially involved a barangay boundary dispute.
Whether, under RA No. 7160, the proper forum for resolving such disputes was the sanggunian rather than the RTC.

Whether Resolution No. 97-89, which delineated the barangay boundaries based on the Cadastral Survey, was validly enacted without following the plebiscite requirement under Section 82 of BP Blg. 337 as alleged by Barangay Mayamot.
Whether the adoption of the resolution resulted in an unauthorized alteration of Barangay Mayamot’s territorial boundaries.

Whether the absence of public consultation and hearing in the preparation and adoption of Resolution No. 97-89 affected its validity.
Whether the proper procedural and remedial measures stipulated under the Local Government Code had been disregarded in resolving the disputed boundaries.