Case Summary (G.R. No. 187349)
Case Background
The case arises from a dispute concerning the territorial boundaries of barangays in Antipolo City, which were redefined by Resolution No. 97-89 passed by the Sangguniang Bayan of Antipolo. This resolution, adopted on October 25, 1989, aimed to delineate the territories of eight new barangays created by Batas Pambansa Nos. 787 to 794 in 1984. Barangay Mayamot contended that the resolution unlawfully reduced its territorial area by reallocating a significant portion of it to neighboring barangays.
Legal Framework
The case was decided under the provisions of the 1987 Philippine Constitution, along with the Local Government Code of 1983 (Batas Pambansa Blg. 337) and the Local Government Code of 1991 (Republic Act No. 7160). The latter statute establishes jurisdictional procedures for boundary disputes.
The Petitioner's Argument
On September 21, 1999, Barangay Mayamot filed a petition before the Regional Trial Court (RTC) of Antipolo City, alleging that Resolution No. 97-89 reduced its territorial jurisdiction without the requisite legislative process or public consultation. The petitioner argued the resolution violated Section 82 of the Local Government Code of 1983, which mandated that any alteration of barangay boundaries must be enacted via ordinance confirmed by a plebiscite.
RTC's Ruling
On August 1, 2006, the RTC dismissed the petition, stating that Resolution No. 97-89 did not alter Barangay Mayamot's boundaries but rather confirmed existing ones based on the Cadastral Survey Plan. The RTC ruled that the case involved a boundary dispute, thus necessitating remedies under the Local Government Code.
Court of Appeals' Ruling
The Court of Appeals upheld the RTC's decision on January 30, 2009, emphasizing that Resolution No. 97-89 was merely procedural and did not change the existing barangay boundaries. The Court stated that the creation of new barangays had been duly ratified through a plebiscite. The appeals court reiterated that the proper forum for resolving such disputes was within the Sangguniang Panlungsod or Sangguniang Bayan, and the RTC had no jurisdiction over boundary disputes.
Jurisdictional Findings
In its review, the Supreme Court underscored the critical determination of jurisdiction based on allegations made within the complaint, as well as the governing law at the time of the acti
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Background of the Case
- The case involves a Petition for Review on Certiorari filed by Barangay Mayamot against various respondents including Antipolo City and its Sangguniang Panglungsod.
- The petition assails the Court of Appeals' Decision dated January 30, 2009, which affirmed the Regional Trial Court's (RTC) Decision dated August 1, 2006, and its Resolution dated March 31, 2009, denying the Motion for Reconsideration.
- The case centers around the legality of Resolution No. 97-89, which Barangay Mayamot claims unlawfully altered its territorial boundaries.
Legislative Framework
- In 1984, Batas Pambansa Bilang (BP Blg.) 787 to 794 were enacted, creating eight new barangays in the Municipality of Antipolo.
- Each of these laws contained provisions regarding the sitios comprising the new barangays, their boundaries, and the required mechanism for their ratification.
- The resolution of territorial boundaries is governed by the Local Government Code of 1983 and subsequent legislation, including Republic Act No. 7160, the Local Government Code of 1991.
Resolution No. 97-89
- On October 25, 1989, the Sangguniang Bayan of Antipolo passed Resolution No. 97-89 to define the boundaries of the newly created and existing barangays.
- The resolution was based on a Cadastral Survey and aimed to prevent administrative conflicts and territorial encroachments among barangays.
- It was unanimously agreed upon by the Sangguniang Bayan and acknowledged by the Association of Barangay Captains (ABC).
Petition of Barangay Mayamot
- Barangay Mayamot filed a petition on September 21, 1999, claiming that Resolution No. 97-89 unlawfull