Case Digest (G.R. No. 241370)
Facts:
Municipality of Bakun, Benguet, herein represented by Mayor Fausto T. Labinio, petitioner, vs. Municipality of Sugpon, Ilocos Sur, herein represented by Mayor Fernando C. Quiton, Sr., respondent, G.R. No. 241370, April 20, 2022, the Supreme Court Third Division, Lopez, M., J., writing for the Court.The dispute concerned a 1,117.20-hectare parcel alleged to lie within the boundaries of either Bakun (Benguet) or Sugpon (Ilocos Sur). The controversy was referred to the Sangguniang Panlalawigan of Ilocos Sur and Benguet, which created a joint committee and on May 12, 2014 issued Joint Resolution No. 1, Series of 2014, adjudicating the area to Bakun.
Aggrieved, Sugpon appealed to the Regional Trial Court (RTC), Branch 25, Tagudin, Ilocos Sur, in SP Proc. No. 01540-T. On April 28, 2015 the RTC reversed Joint Resolution No. 1, holding that Act Nos. 1646 and 2877 could not support Bakun’s claim because they did not specifically delineate the metes and bounds between the two municipalities; the RTC credited Sugpon’s documentary evidence (maps, certifications) and adjudicated the disputed 1,117.20 ha. to Sugpon. A July 27, 2015 RTC resolution addressed related proceedings; Bakun’s motion for reconsideration was denied.
Bakun elevated the case to the Court of Appeals (CA). In a Decision dated February 1, 2018 the CA denied Bakun’s petition and affirmed the RTC in toto, applying the preponderance-of-evidence standard appropriate to boundary disputes and finding Sugpon’s maps and public documents persuasive. The CA denied Bakun’s motion for reconsideration in a July 6, 2018 Resolution.
Bakun filed a petition for review on certiorari under Rule 45 of the Rules of Court before the Supreme Court, challenging the factual findings and the RTC/CA weighing of evidence. The parties’ submissions focused on documentary proof: Sugpon relied on administrative and land classification maps, a DENR certification, a DAR certification, tax declarations, school division and election certifications, a Certificate of Ancestral Domain Title, a...(Subscriber-Only)
Issues:
- Under Rule 45, may the Supreme Court re-examine and re-weigh the factual findings of the RTC and CA in this boundary dispute?
- On the merits, does the preponderance of evidence show the disputed 1,117.20 ha. falls within the territorial jurisdiction of Sugpon rather than Bakun, and do Act Nos. 1646 and 2877 fix the municip...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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