Title
City of Caloocan vs. City of Malabon
Case
G.R. No. 269159
Decision Date
Nov 4, 2024
Caloocan challenged the constitutionality of RA 9019, asserting it altered boundaries without a plebiscite. The CA overturned the RTC's ruling, deeming a proper administrative route necessary before judicial action.

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)

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