Title
Supreme Court
City of Pasig vs. Commission on Elections
Case
G.R. No. 125646
Decision Date
Sep 10, 1999
Boundary dispute between Pasig and Cainta over proposed barangays; plebiscites suspended pending resolution of territorial jurisdiction.

Case Digest (G.R. No. 125646)
Expanded Legal Reasoning Model

Facts:

  • Creation of proposed barangays in Pasig City
    • On April 22, 1996, residents of Karangalan Village petitioned to separate from Barangays Manggahan and Dela Paz, Pasig City. The Pasig City Council approved Ordinance No. 21, Series of 1996, creating Barangay Karangalan, with a plebiscite scheduled on June 22, 1996.
    • On September 9, 1996, the Pasig City Council approved Ordinance No. 52, Series of 1996, creating Barangay Napico, with its plebiscite set for March 15, 1997.
  • Boundary dispute and COMELEC petitions
    • The Municipality of Cainta filed petitions with COMELEC (UND Nos. 96-016 and 97-002) to suspend or cancel the Karangalan and Napico plebiscites, invoking Civil Case No. 94-3006 pending before the Regional Trial Court of Antipolo, involving a boundary dispute with Pasig City.
    • In UND No. 96-016, COMELEC held the Karangalan plebiscite in abeyance pending final resolution of the dispute. In UND No. 97-002, COMELEC dismissed the Napico petition as moot after the plebiscite ratified its creation.
  • Elevation to the Supreme Court
    • G.R. No. 125646: City of Pasig petitioned to set aside COMELEC’s suspension order in UND No. 96-016.
    • G.R. No. 128663: Municipality of Cainta challenged COMELEC’s dismissal in UND No. 97-002 and sought annulment of the Napico plebiscite results.

Issues:

  • Whether the plebiscites for the creation of Barangays Karangalan and Napico should be suspended or cancelled pending final resolution of the boundary dispute between Pasig City and Cainta.
  • Whether a plebiscite already held (Napico) can still be annulled despite a fait accompli.
  • Whether the COMELEC correctly applied the prejudicial question doctrine in the two petitions.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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