G.R. No. 128938 - Soriano vs. Court of Appeals

Petitioner: Municipality of Candijay, Bohol, acting through its Sanguniang Bayan and Mayor.
Respondents: Court of Appeals and Municipality of Alicia, Bohol.

The Municipality of Candijay filed a complaint for settlement of boundary dispute and quieting of title over Barrio Pagahat against the Municipality of Alicia before the Regional Trial Court (RTC) of the City of Tagbilaran, Bohol (Civil Case No. 2402).
The RTC ruled in favor of Candijay, declaring Barrio Pagahat within its territorial jurisdiction, permanently enjoining Alicia from interfering with Candijay’s possession and political supervision over the barrio.
The Court of Appeals (CA) reversed the RTC decision, holding that Barrio Pagahat does not fall under Candijay’s territory and criticized the boundary claims supported by petitioner as expansive and inconsistent with legislative and executive acts establishing Alicia’s territory.

The CA examined survey plans submitted by both parties and found both inadequate in defining the boundary monuments between Candijay and Municipality of Mabini.
The CA noted that Executive Order No. 265 (1949), which created Alicia from barrios of Mabini, clearly included barrios under Alicia’s jurisdiction, but Barrio Bulawan (origin of Pagahat) was not among those barrios.
Act No. 968 (1903), outlining component territories of Mabini and Candijay, did not explicitly include Barrio Pagahat as part of Candijay either.

Petitioner questioned Alicia’s juridical personality, arguing that Executive Order No. 265 creating Alicia was void due to unconstitutional delegation of legislative powers.
Petitioner invoked the Supreme Court ruling in Pelaez vs. Auditor General (1965), which declared delegation invalid on the basis of Section 68 of the Revised Administrative Code.
Petitioner sought to bar Alicia from presenting evidence on this ground during trial, about 35 years after Alicia’s creation.

The Supreme Court cited Municipality of San Narciso, Quezon vs. Mendez, Sr. (1994), where the Court held that despite defects in creation, long continuing recognition and exercise of authority create a de facto municipality with de jure status due to curative provisions under the Local Government Code (R.A. No. 7160).
The Court compared Alicia's situation with San Andres, emphasizing Alicia's recognized existence for decades, including classifications, inclusion in municipal circuits, and legislative apportionment under the 1987 Constitution.

Whether the Court of Appeals erred in reversing the RTC's declaration that Barrio Pagahat is within the territorial jurisdiction of Municipality of Candijay.
Whether the Court of Appeals erred in applying the principle of equiponderance of evidence to dismiss the case for lack of preponderance by either party.
Whether the Municipality of Alicia lacks juridical personality due to the purported invalidity of Executive Order No. 265 for unconstitutional delegation of legislative power.
Whether the dismissal of the complaint leaves the parties without relief, thus failing to resolve the territorial dispute properly.