Case Digest (G.R. No. 269159) Core Legal Reasoning Model
Facts:
The case arose from a petition filed by Henry P. Cammayo, a former Sangguniang Panlungsod member of Caloocan, together with former barangay chairpersons and kagawads from Barangays 160 and 161 of Caloocan City, challenging the constitutionality and validity of Republic Act No. (RA) 9019. RA 9019, enacted on March 5, 2001, converted the then Municipality of Malabon into a highly urbanized city (HUC) and defined Malabon’s territorial boundaries, which allegedly included portions of barangays historically part of Caloocan. The electorates of Malabon had ratified this conversion in a plebiscite on April 21, 2001. The petitioners contended that Section 2 of RA 9019 substantially altered Caloocan’s boundaries without conducting the plebiscite required under Article X, Section 10 of the 1987 Philippine Constitution and the Local Government Code (LGC), thus violating constitutional and statutory mandates.
The petition for declaratory relief was filed on September 10, 2002, against the
Case Digest (G.R. No. 269159) Expanded Legal Reasoning Model
Facts:
- Enactment of RA 9019 and creation of City of Malabon as a Highly Urbanized City (HUC)
- On March 5, 2001, Republic Act No. 9019 (RA 9019) was enacted, converting the Municipality of Malabon into a Highly Urbanized City (HUC), named the City of Malabon.
- RA 9019 took effect immediately on March 5, 2001.
- Pursuant to Section 54 of RA 9019, a plebiscite was conducted on April 21, 2001, where the electorate ratified Malabon's conversion to an HUC.
- Definition of boundaries under Section 2 of RA 9019
- RA 9019 Section 2 specified the boundaries of the City of Malabon with detailed technical descriptions, including coordinates and specific natural and man-made landmarks.
- The boundaries indicated that portions of the subject barangays — particularly Barangays 160 and 161 (Libis and Baesa areas) — formerly perceived as part of Caloocan, were included within the territorial jurisdiction of Malabon.
- Petitioner's claims and filing of petition
- Henry P. Cammayo, a former member of the Caloocan Sangguniang Panlungsod, along with others (collectively "Cammayo et al."), filed a petition for declaratory relief on September 10, 2002 against Malabon city officials and later the Republic of the Philippines.
- The petition alleged:
- Section 2 of RA 9019 substantially altered Caloocan's boundaries without plebiscite conduct in violation of Article X, Section 10 of the 1987 Constitution.
- The subject barangays had historically been part of Caloocan with registered voters participating in Caloocan elections and titling and tax payments in Caloocan.
- No plebiscite had been conducted in these barangays to approve the boundary alteration.
- Preliminary injunction was granted by the RTC in favor of the petitioners.
- Position of the City of Malabon
- Malabon argued that the disputed territories had always been under Malabon jurisdiction.
- It contested the legal standing of Cammayo et al. as the matter primarily concerned Caloocan.
- Malabon maintained that the plebiscite conducted on April 21, 2001, was sufficient and no separate plebiscite for these barangays was necessary.
- Asserted that the proper procedure to resolve boundary disputes was administrative under Sections 118 and 119 of the Local Government Code (LGC), not through declaratory relief.
- Trial testimonies and evidence
- Petitioners presented testimonies, maps, survey plans, and government agency certifications to establish Caloocan's historical jurisdiction over the subject barangays.
- Malabon presented technical surveys, cadastral plans, and tax records asserting longstanding jurisdiction over the area.
- Both parties produced evidence demonstrating conflicting claims to the same territories.
- RTC Decision
- On January 28, 2019, the RTC declared RA 9019 unconstitutional and void for failing to comply with the plebiscite requirement.
- The court permanently enjoined Malabon from exercising jurisdiction over the contested areas.
- Appeal and CA Decision
- Malabon appealed; the CA reversed and set aside the RTC decision via February 28, 2023 decision.
- The CA held that the case was a boundary dispute that should first be referred to the respective Sanggunians of Malabon and Caloocan as per Sections 118 and 119 of the LGC.
- The CA dismissed the case without prejudice, lifting the previous injunction.
- Caloocan's Reconsideration and Present Petition
- Caloocan's motion for reconsideration was denied by the CA on August 24, 2023.
- Caloocan filed the present Petition for Review on Certiorari challenging the CA ruling.
Issues:
- Whether the Court of Appeals erred in reversing the RTC decision declaring RA 9019 unconstitutional.
- Whether Section 2 of RA 9019, which defines the boundaries of Malabon and includes portions of Caloocan’s barangays, violated the constitutional requirement of conducting a plebiscite under Article X, Section 10 of the 1987 Constitution.
- Whether a petition for declaratory relief was the proper remedy to contest the constitutionality and validity of RA 9019 instead of exhausting administrative remedies under the LGC.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)