Case Summary (G.R. No. 83942)
Key Dates and Applicable Law
Relevant dates from the record: Sangguniang Bayan Resolution No. 75-96 (November 14, 1996); RTC Decision (April 27, 2000); RTC Order denying reconsideration (December 20, 2000); Court of Appeals Decision dismissing appeal (October 17, 2002) and its Resolution (August 25, 2003); Supreme Court decision resolving the petition. Governing legal framework applied in the decision: 1987 Philippine Constitution (as applicable to cases decided after 1990), Local Government Code of 1991 (Sections 118 and 119), Rules of Court (Rule 41, Rule 42, Rule 44 Section 13, Rule 45), Batas Pambansa Blg. 129 Section 22 (as cited regarding appeals from RTC exercising appellate jurisdiction), and the Rules and Regulations Implementing the Local Government Code (Article 17, Rule III).
Procedural History
The dispute originated before the Sangguniang Bayan of Lemery, which referred the matter to a hearing committee that recommended recognition of the lots as within Barangay Sangalang. The Sangguniang Bayan adopted that recommendation in Resolution No. 75-96. Respondent appealed to the Regional Trial Court under Section 119 of the Local Government Code; the RTC, acting in its appellate capacity, reversed the sanggunian and declared the lots within Barangay Maguihan. Petitioner sought reconsideration at the RTC (denied) and then filed a Notice of Appeal (later amended) to the Court of Appeals. The CA dismissed the appeal on procedural grounds for using the wrong remedy and for noncompliance with briefing requirements. Petitioner filed a Rule 45 petition to the Supreme Court challenging the CA dismissal and the RTC’s purported lack of appellate jurisdiction and factual conclusions.
Issues Presented to the Supreme Court
Petitioner’s assignments of error included: (A) that the CA committed grave abuse by dismissing the appeal on procedural technicalities instead of resolving the case on the merits; (B) that the RTC’s reversal of Resolution No. 75-96 was void because respondent failed to perfect its appeal and thus the RTC lacked appellate jurisdiction; and (C) that the RTC abused its discretion by substituting its judgment for that of the Sangguniang Bayan despite substantial evidence supporting the sanggunian’s resolution.
Supreme Court’s Procedural Analysis — Mode of Appeal and Docket Fees
The Supreme Court examined whether the remedy pursued by petitioner was proper. It agreed with the CA that, because the RTC took the case in its appellate jurisdiction (as contemplated by Section 118 and Section 119 of the Local Government Code), further appeal to the Court of Appeals should have been by petition for review under Rule 42 rather than by ordinary appeal under Rule 41. The Court nonetheless recognized the jurisprudential trend favoring liberal construction of procedural rules to promote substantial justice (citing authorities in the record) and cautioned against rigidly applying technicalities. On the related contention about docket fees, the Court recalled precedent that failure to pay appellate docket fees does not automatically mandate dismissal. The RTC’s apparent acceptance of respondent’s explanation regarding nonpayment led the Supreme Court to decline interference with the RTC’s exercise of discretion in the absence of proof of bias or prejudice.
Supreme Court’s Analysis on CA’s Dismissal for Technical Noncompliance
While recognizing that petitioner availed itself of the wrong procedural vehicle (Rule 41 rather than Rule 42), the Supreme Court concluded that the CA should not have dismissed the petition so readily on the combined basis of the wrong remedy and strict application of Rule 44 Section 13 (subject index and page references), given the limited size of the record (short brief, few documents, no testimonial evidence) and the public interest in resolving local-government boundary claims on the merits. The Court therefore found the CA’s strict reliance on these technical requirements to be excessive in the circumstances.
Substantive Merits — Evidentiary Framework for Boundary Disputes
Article 17, Rule III of the Implementing Rules of the Local Government Code prescribes the documents and procedures for boundary disputes, including maps duly certified by the Land Management Bureau (LMB)/LMB-approved maps, technical descriptions, assessor certifications, and declarations of residents. The RTC observed, and the Supreme Court agreed, that neither party had furnished the full complement of documents enumerated in the implementing rules; therefore the Court had to weigh the evidence presented and determine which documents carried greater probative value.
Evidentiary Weighing — Cadastral Map versus Assessor Records
Petitioner relied on certifications from the provincial assessor, tax declarations, and an old barangay map. Respondent presented a cadastral map of the Lemery cadastre approved by the Director of Lands (approved March 17, 1986) and a CENRO/DENR certification. The Supreme Court credited the RTC’s conclusion that maps and certifications produced by the Land Management Bureau (and related DENR offices), prepared and approved by g
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Case Caption, Citation and Nature of Proceeding
- G.R. No. 159792; Decision promulgated December 23, 2009; reported at 623 Phil. 711, Third Division; Decision penned by Justice Peralta.
- Petition for Review on Certiorari under Rule 45 of the Rules of Court seeking to set aside:
- Court of Appeals (CA) Decision dated October 17, 2002 in CA-G.R. CV No. 70021; and
- CA Resolution dated August 25, 2003 denying reconsideration.
- Parties: Petitioner — Barangay Sangalang, represented by its Chairman Dante C. Marcellana; Respondent — Barangay Maguihan, represented by its Chairman Arnulfo Villarez.
- Relief sought: Annulment/reversal of CA action and restoration of Sangguniang Bayan resolution recognizing disputed lots as within Barangay Sangalang; or other appropriate relief.
Factual Background
- Core dispute: Territorial jurisdiction over properties covered by Tax Declaration Nos. 038-00315, 038-00316, and 038-00317, located in Lemery, Batangas.
- Petitioner’s position: The lots covered by those tax declarations lie within Barangay Sangalang’s territorial jurisdiction.
- Respondent’s position: The same lots lie within Barangay Maguihan’s territorial boundary.
- Initial administrative process:
- Dispute lodged before the Sangguniang Bayan of Lemery; referred to a hearing committee.
- Hearing committee rendered a report concluding the disputed properties belonged to petitioner (Rollo, pp. 46–47).
- Sangguniang Bayan adopted the committee’s recommendation in Resolution No. 75-96, dated November 14, 1996, resolving to recognize the areas covered by TD Nos. 038-00315, 038-00316 and 038-00317 as within the territorial jurisdiction of Barangay Sangalang (Rollo, pp. 48–49).
Administrative and Judicial Course
- Appeal to Regional Trial Court (RTC):
- Respondent appealed the Sangguniang Bayan Resolution to the RTC pursuant to Section 119 of the Local Government Code; docketed as Barangay Jurisdiction Dispute No. 1.
- RTC Decision dated April 27, 2000 reversed and set aside Resolution No. 75-96, and adjudged Lot Nos. 4469 and 6650 (embraced in TD Nos. 038-00315, 038-00316, 038-00317) as within the territorial jurisdiction of Barangay Maguihan; ordered assessors to correct records (Rollo, pp. 58–60).
- Petitioner filed Motion for Reconsideration; RTC denied it by Order dated December 20, 2000 (Rollo, pp. 61–66).
- Appeal to Court of Appeals:
- Petitioner filed a Notice of Appeal (later amended) and proceeded to CA.
- CA Decision dated October 17, 2002 dismissed the appeal; CA ruled petitioner availed of the wrong remedy (filed ordinary appeal under Rule 41 instead of petition for review under Rule 42) because the RTC acted in appellate jurisdiction (Rollo, pp. 36–41).
- CA further ruled that even if treated as ordinary appeal under Rule 41, petitioner’s brief violated Section 13, Rule 44 (lack of subject index and page references) and thus dismissal was warranted (Rollo, p. 40).
- Petitioner’s motion for reconsideration to the CA was denied by Resolution dated August 25, 2003 (Rollo, pp. 44–45).
- Elevation to the Supreme Court:
- Petitioner filed the present Rule 45 Petition for Review on Certiorari to set aside the CA Decision and Resolution.
Assignments of Error Raised by Petitioner
- A. Alleged grave abuse of discretion by the CA in dismissing petitioner’s appeal based on technicalities, overriding substantial justice and established Supreme Court precedents.
- B. Asserted that the RTC Decision (and its Annexes) reversing Sangguniang Bayan Resolution No. 75-96 is null and void because respondent did not perfect its appeal, thus depriving the trial court of appellate jurisdiction.
- C. Allegation that the RTC committed grave abuse of discretion and substituted its own judgment over the Sangguniang Bayan’s judgment, which was supported by substantial evidence.
Procedural Issues Identified by the Supreme Court
- Primary procedural question: Whether petitioner availed of the correct mode of appeal from the RTC Decision that exercised appellate jurisdiction.
- Secondary procedural matter: Whether non-payment of appellate docket fees by respondent (as raised by petitioner in supplemental motions) justified certain rulings or dismissals, and whether the RTC properly exercised discretion regarding docket fees.
- Court’s observation of petitioner’s inconsistent stance regarding strict application of procedural rules — faulting the CA for strictness when unfavorable yet faulting the RTC for lack of strictness on docket fees when favorable.
Legal Provisions and Rules Applied
- Local Government Code:
- Section 118: Jurisdictional responsibility for settlement of boundary disputes lodged before the Sangguniang Panlungsod or Sangguniang Bayan when involving barangays within same city/municipality; Sanggunian must decide within 60 days from certification if amicable settlement fails (Rollo, p. 39).
- Section 119: Provides for appeal of sanggunian decision to the proper RTC within time and manner prescribed by Rules of Court; RTC shall decide within one year (Rollo, note 7).
- Rules of Court:
- Rule 41, Sec. 2(a)–(b): Modes of appeal — distinguishes ordinary appeal (to CA from RTC decisions in exercise of original jurisdiction) and petition for review (to CA under Rule 42 from RTC decisions in exercise of appellate jurisdiction). Supreme Court relied on this to conclude petitioner invoked wrong remedy (Rollo, p. 39–40).
- Rule 44, Section 13: Requirements for appellant’s brief — subject index and page references; CA relied on this provision in dismissing even if appeal were treated as ordinary appeal (Rollo, p. 40).
- Rules and Regulations Implementing the Local Government Code:
- Article 17, Rule III: Procedures for settling boundary disputes and list of documents to be attached to petition, including LMB-certified maps and assessor certifications among others (Rollo, text of Art. 17).
Precedents and Authorities Cited in the Decision
- Yambao v. Court of Appeals, 399 Phil. 712, 718–719 (2000): Court’s guidance that failure to pay appellate docket fees does not automatically result in dismissal, and courts should ensure a