G.R. No. 159792 - Barangay Sangalang vs. Barangay Maguihan

The controversy arose from a boundary dispute between two barangays in Lemery, Batangas: Barangay Sangalang (petitioner) and Barangay Maguihan (respondent).
The dispute centered on the territorial boundaries covering properties identified by Tax Declaration Nos. 038-00315, 038-00316, and 038-00317.

The case was first lodged before the Sangguniang Bayan, which then referred it to a hearing committee.
The hearing committee rendered a report recommending that the properties in dispute belong to Barangay Sangalang.
Following this recommendation, the Sangguniang Bayan of Lemery, Batangas, passed Resolution No. 75-96 on November 14, 1996, recognizing the disputed areas as being within the territorial jurisdiction of Barangay Sangalang.

Respondent appealed the Sangguniang Bayan decision to the RTC under Section 119 of the Local Government Code.
On April 27, 2000, the RTC rendered a decision reversing Resolution No. 75-96 and declared that the lots covered by the stated tax declarations were within the jurisdiction of Barangay Maguihan.
A Motion for Reconsideration by petitioner was denied by the RTC on December 20, 2000, after which petitioner filed a Notice of Appeal, later amended.

On October 17, 2002, the CA dismissed petitioner’s appeal, ruling that the petitioner had availed the wrong remedy by filing a Notice of Appeal under Rule 41 instead of a petition for review under Rule 42.
The CA further relied on technical deficiencies in the appellant’s submitted brief, specifically the lack of a subject index and page references as required by Section 13 of Rule 44 of the 1997 Rules of Procedure.
Petitioner’s subsequent Motion for Reconsideration before the CA was denied on August 25, 2003.

Certification from the Office of the Provincial Assessor stating that the area covered by the disputed tax declarations was within Barangay Sangalang.
Copies of Tax Declaration Nos. 038-00315, 038-00316, and 038-00317.
An old map of Barangay Sangalang.

A certified copy of the cadastral map of the Lemery Cadastre approved by the Director of Lands (Department of Environment and Natural Resources) on March 17, 1983.
Certification from the Community Environment and Natural Resources Office dated September 9, 1997.

Procedural documents required under Article 17, Rule III of the Rules and Regulations Implementing the Local Government Code of 1991 were noted, though neither party had attached all enumerated documents to the petition.

Petitioner contended that dismissing the appeal solely on technical grounds deprived the party of substantial justice.
Petitioner argued that the trial court’s judgment should have been reconsidered in light of substantial evidence, particularly regarding local government jurisdiction issues.

Whether petitioner availed itself of the wrong remedy by filing an ordinary appeal under Rule 41 instead of a petition for review under Rule 42, given that the RTC rendered its decision in the exercise of appellate jurisdiction.
Whether the strict application of technical requirements (i.e., the non-payment of docket fees, and the absence of a subject index and page references in the appellant’s brief) should override the substantial merits of the case.
Which barangay’s jurisdiction is controlling over the disputed properties, based on the weight of evidence submitted by the parties, particularly the contrast between documents issued by the tax assessor’s office versus those issued by the Land Management Bureau (LMB).