G.R. No. 98045 - Vda. de Nazareno vs. Court of Appeals

The Municipality of Pateros filed a complaint claiming portions of Fort William McKinley (now Fort Bonifacio) including Barangays Cembo, South Cembo, West Rembo, East Rembo, Comembo, Pembo, Pitogo, and Bonifacio Global City, were originally part of Pateros but were declared to be part of Makati by Presidential Proclamations Nos. 2475 and 518 issued in 1986 and 1991.
Taguig also filed a separate complaint challenging the constitutionality of the same proclamations, asserting its territorial claim over parts of Fort Bonifacio.
Pateros sought to intervene in Taguig’s case but was denied due to pending case before RTC Makati.

RTC Pasig, Branch 153 ruled in favor of Taguig in 2011, invalidating the proclamations to the extent that they diminished Taguig's territory without a plebiscite.
Makati filed motions for reconsideration and petitions which were denied or dismissed as premature.
The Supreme Court, in G.R. No. 235316, ruled that Taguig had superior claim over the disputed area versus Makati, and accounted for the nature of the evidence and legal basis rejecting Makati’s claims.
Meanwhile, Pateros’ initial case was dismissed for lack of jurisdiction and failure to comply with procedural requirements under the Local Government Code (LGC). The Court directed parties to settle disputes amicably via sanggunians (local councils) as mandated by the LGC.

Pateros formally requested dialogue with both Makati and Taguig sanggunians towards amicable settlement as required by Section 118 of the LGC and the implementing rules.
Makati engaged in dialogues with Pateros, but no settlement was reached partly due to the ongoing conflict between Makati and Taguig.
Taguig failed to respond to Pateros’ requests for dialogue.
Consequently, Pateros’ Sangguniang Bayan passed unilateral resolutions declaring failure to reach an amicable settlement and certified the dispute for formal trial.

Pateros filed Civil Case No. 73387-TG before RTC Pasig against Makati and Taguig seeking judicial declaration that Parcel 4, Survey Plan Psu-2031 is within Pateros’ territory.
Taguig moved to dismiss the case on grounds of forum shopping and failure to comply with procedural requirements of the LGC.
Makati filed an answer and motion to dismiss, asserting the RTC lacked jurisdiction, faulting non-compliance with the LGC and claiming prescription and failure to state a cause of action.
RTC Pasig granted Makati’s motion to dismiss for lack of jurisdiction, holding that Pateros failed to comply with the joint sanggunians’ settlement procedure under the LGC and its rules.
On appeal, the Court of Appeals (CA) affirmed the dismissal, ruling that original jurisdiction over boundary disputes lies with the sanggunians acting jointly, and the RTC has only appellate jurisdiction after sanggunian decision.

Whether Pateros complied with the procedural requirements of Sections 118(d) and 118(e) of the Local Government Code and Rule III of its Implementing Rules and Regulations (IRR), as directed by the Supreme Court in G.R. No. 157714.
Whether the failure of the Taguig Sanggunian to respond to Pateros’ resolutions seeking settlement through council-to-council dialogue justified the filing of the complaint for judicial declaration in Civil Case No. 73387-TG.
Whether the Regional Trial Court (RTC) of Pasig, Branch 271, has jurisdiction over Civil Case No. 73387-TG involving boundary dispute among Pateros, Makati, and Taguig.