Case Digest (G.R. No. 243167)
Facts:
The Municipality of Payao, Zamboanga Sibugay v. The Municipality of Imelda, Zamboanga Sibugay, G.R. No. 243167, June 28, 2021, the Supreme Court Third Division, Lopez, J., writing for the Court.The parties are the Municipality of Payao (petitioner) and the Municipality of Imelda (respondent). Both are local government units created under Presidential Decrees—P.D. No. 1238 (Payao) and P.D. No. 1239 (Imelda)—and are geographically adjacent; Barangay Guintolan lies along their common boundary, giving rise to a territorial and supervisory dispute.
In 1987 the Sangguniang Panlalawigan of Zamboanga del Sur adopted Resolutions Nos. 166 and 188 approving the transfer of Barangay Guintolan from Payao to Imelda. The Municipality of Payao filed a Petition for Declaratory Relief before Branch 19, Regional Trial Court (RTC) of Pagadian City, which in a November 18, 1987 decision declared Resolution No. 166 null and void, holding that municipal boundaries could be altered only by the Batasang Pambansa.
Imelda previously filed a Petition for Mandamus before RTC–Pagadian, Branch 21, which was dismissed by Order dated August 15, 2001. Administrative and provincial attempts at resolution followed: Imelda’s Sangguniang Bayan passed a resolution in 2006 requesting transfer, provincial officials exchanged correspondence, and the Provincial Legal Office (May 2, 2011 memorandum) advised that the controversy concerned the proper station of the barangay rather than a boundary dispute.
On August 22, 2011 the Municipality of Imelda filed a Petition for Mandamus before the Regional Trial Court of Ipil (docketed as Special Civil Action No. I-115), alleging that P.D. No. 1239 and DENR maps placed Barangay Guintolan within Imelda; Payao opposed on grounds that mandamus was improper and that the case was barred by res judicata. Branch 31 of the RTC–Imelda granted the petition in a Decision dated April 1, 2015, ordering Payao to cease exercising jurisdiction and to peacefully turn over control and supervision of Barangay Guintolan; the RTC denied reconsideration on May 22, 2015.
Payao appealed to the Court of Appeals (Twenty‑Second Division) in CA‑G.R. SP No. 07137‑MIN, which in a Decision dated February 28, 2018 affirmed the RTC and held that the requisites for mandamus were satisfied and res judicata did not apply; the Court of Appeals denied Payao’s motion for reconsideration in a September 21, 2018 Resolution. Thereafter, on December 21, 2018, ...(Pro-only)
Issues:
- Whether mandamus is an appropriate remedy for the Municipality of Imelda to secure jurisdiction (supervisory authority) over Barangay Guintolan to the exclusion of the Municipality of Payao.
- Whether the second Petition for Mandamus filed by the Municipality of Imelda is bar...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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