Case Digest (G.R. No. 235316) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On November 22, 1993, the Municipality of Taguig (now City of Taguig) filed Civil Case No. 63896 before the Regional Trial Court of Pasig (Branch 153) against the Municipality of Makati (now City of Makati), contesting territorial jurisdiction over the Enlisted Men’s Barangays (EMBOs) and the entirety of Fort Andres Bonifacio (formerly Fort William McKinley). Taguig alleged that Presidential Proclamations 2475 (1986) and 518 (1990) unilaterally altered its boundaries without a plebiscite, violating Article X, Section 10 of the 1987 Constitution, and produced Spanish-era deeds, the 1909 US survey Plan Psu-2031, and successive cadastral maps (MCadm-590-D for Taguig, MCadm-571-D for Makati) showing Parcels 3 and 4 of Psu-2031 within Taguig. Makati countered that the disputed lands formed part of the historic Hacienda Maricaban sold in 1902 and 1908 to the US, included in its 1979 and 1994 cadastral surveys, recognized as Makati barrios in census records (1918, 1948, 1970–1980, 1990 Case Digest (G.R. No. 235316) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the dispute
- On November 22, 1993, the Municipality of Taguig (now City of Taguig) filed Civil Case No. 63896 before RTC Pasig, seeking judicial confirmation of its boundary over the Enlisted Men’s Barangays (EMBOs) and Inner Fort in Fort Bonifacio, and nullification of Proclamations 2475 (1986) and 518 (1990).
- Taguig alleged these proclamations unconstitutionally altered its territory without plebiscite; Makati (now City of Makati) denied jurisdiction over the disputed areas.
- Parties’ contentions
- Taguig’s version:
- Historical existence as a pueblo; U.S. acquisitions of Hacienda Maricaban in 1902 and 1908; Psu-2031 (approved 1909) divided Fort McKinley into Parcels 1–4, showing Parcels 3–4 in Taguig.
- Successive proclamations (1957–1973) and cadastral mappings (MCadm-590-D for Taguig, MCadm-571-D for Makati) confirm Parcels 3–4 in Taguig.
- BCDA reconstitution (1995) and Special Patents (1995) conveyed lands in Taguig.
- Makati’s version:
- Only the 1902 sale (northeast portion) became Fort McKinley within Makati; remaining Hacienda Maricaban (OCT 291, 1906) excluded Fort.
- U.S. census (1918, 1948) listed Fort McKinley as a Makati barrio.
- EMBOs and Inner Fort Barangays established under Makati (PD 557, 1974); appeared in censuses (1970–1990) and Makati’s 1994 numerical cadastral survey.
- Procedural history
- RTC Decision (July 8, 2011): ruled for Taguig, confirmed Parcels 3–4 under Taguig, declared Procs 2475 and 518 invalid, made preliminary injunction permanent.
- CA Seventh Division: in CA-G.R. SP 120495, dismissed Makati’s petition for annulment of judgment (2012–2013), found premature but did not resolve forum-shopping conclusively.
- CA Sixth Division (July 30, 2013): in CA-G.R. CV 98377, reversed RTC on merits, held disputed areas within Makati; deferred forum-shopping issue as moot.
- Supreme Court in G.R. No. 208393 (June 15, 2016): found Makati guilty of willful and deliberate forum shopping, fined counsel P2,000 each, but did not dismiss the appeal.
- CA Sixth Division Resolutions (March 8 & October 3, 2017): relying on SC’s forum-shopping finding, dismissed Makati’s appeal with prejudice, prompting this Rule 45 petition.
Issues:
- Did Makati’s proven forum shopping warrant dismissal of its CA appeal?
- On the merits, did Taguig prove by preponderance of evidence that Parcels 3–4 (Fort Bonifacio) lie within its jurisdiction?
- Do Proclamations 2475 (1986) and 518 (1990) unconstitutionally alter Taguig’s boundary without plebiscite?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)