Case Digest (G.R. No. 269159)
Facts:
The City of Caloocan v. The City of Malabon et al., G.R. No. 269159, November 04, 2024, the Supreme Court Second Division, Kho, Jr., J., writing for the Court. The petition under Rule 45 was filed by the City of Caloocan, represented by Mayor Dale Gonzalo R. Malapitan, assailing the Court of Appeals Decision dated February 28, 2023 and Resolution dated August 24, 2023 in CA‑G.R. SP No. 164434, which had reversed Branch 121 of the Regional Trial Court, Caloocan City’s January 28, 2019 decision that declared Republic Act No. 9019 (the Charter of the City of Malabon) invalid.RA 9019, enacted March 5, 2001 and effective immediately, converted the Municipality of Malabon into a highly urbanized city; Section 2 of RA 9019 supplied a technical metes‑and‑bounds description of Malabon's boundaries. Claiming Section 2 altered Caloocan’s territorial jurisdiction by including portions of Barangays 160 and 161 (Libis, Baesa) without plebiscitary approval, Henry P. Cammayo and other former Caloocan officials (collectively, Cammayo et al.) filed a Petition for declaratory relief on September 10, 2002 against the City of Malabon, its mayor and councilors. The RTC granted a preliminary injunction on October 10, 2002.
Cammayo et al. later amended their petition to implead the Republic; the City of Caloocan moved to intervene (admitted August 24, 2004) asserting ownership and administrative control over the subject barangays and seeking declaration of Section 2’s unconstitutionality for failing the plebiscite requirement under Article X, Section 10 of the Constitution and RA 7160 (the Local Government Code). Malabon answered, contending the contested territory had historically been part of Malabon, that a plebiscite for Malabon’s cityhood covered the city, and that the proper remedy for a boundary dispute lies under Sections 118–119 of the Local Government Code of 1991 (LGC).
After trial, the RTC (Decision of January 28, 2019) declared RA 9019 invalid and made permanent the preliminary injunction, holding Section 2 altered Caloocan’s boundaries without plebiscitary approval. Malabon’s motion for reconsideration was denied and it appealed to the Court of Appeals.
The Court of Appeals (Decision February 28, 2023) reversed the RTC, dismissed the case without prejudice, lifted the injunction, and held the controversy to be a boundary dispute that should first be jointly referred ...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in reversing the RTC and dismissing the petition on the ground that the controversy is a boundary dispute requiring prior joint referral to the Sanggunians under Sections 118 and 119 of the LGC and Rule III of its IRR?
- If the foregoing is incorrect, is Section 2 of RA 9019 unconstitutional for failing to secure a plebiscite in the barangays allegedly affected, in violation of Artic...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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