Case Digest (G.R. No. 220824)
Facts:
Municipality of Pateros filed Civil Case No. 73387-TG on March 27, 2012 before the Regional Trial Court of Pasig City, Branch 271, against City of Makati and City of Taguig, seeking declaration that Parcel 4, Psu-2031 is within Pateros and nullification of Presidential Proclamations; the RTC granted Makati’s motion to dismiss on May 10, 2013. The Court of Appeals dismissed Pateros’ appeal on January 29, 2015, prompting a petition for review under Rule 45 to this Court (G.R. No. 220824).
Issues:
- Did Pateros comply with the requirements of Sec. 118(d) and (e) of the Local Government Code of 1991 and Rule III of its IRR as directed in G.R. No. 157714?
- Does the failure of the Taguig Sanggunian to respond to settlement requests justify Pateros’ filing of Civil Case No. 73387-TG against Taguig and Makati?
- Has the Regional Trial Court of Pasig, Branch 271 jurisdiction over Civil Case No. 73387-TG?
Ruling:
The petition was GRANTED. The Court REVERSED and SET ASIDE the January 29, 2015 Decision and September 24, 2015 Resolution of the Court of Appeals, and DIRECTED the Regional Trial Court of Pasig City, Branch 271 to reinstate Civil Case No. 73387-TG and proceed with dispatch. The Court held that, notwithstanding Pateros’ imperfect compliance with the statutory procedure, the circumstances justified original judicial action and conferred jurisdiction on the RTC.
Ratio:
The Court recognized that Sec. 118, Sec. 119 of the Local Government Code of 1991 and Rule III vest primary jurisdiction to settle boundary disputes in the respective sanggunians acting jointly, but interpreted those provisions in light of precedent. Citing Municipality of Pateros v. Court of Appeals and Province of Antique v. Judge Calabocal, the Court held that when a contending LGU’s silence or refusal renders the prescribed amicable settlement procedure impossible, the initiating LGU may seek judicial recourse by filing an original action; under the facts Taguig’s inaction effected failure of settlement and did not bar Pateros from litigating. The Court further found that the finality of G.R. No. 235316 did not operate as res judicata against Pateros because of the absence of identity of parties and causes of action.
Doctrine:
- Sec. 118 and Sec. 119, LGC, and Rule III of the IRR prescribe joint sanggunian settlement as the primary mechanism for LGU boundary disputes.
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