Case Summary (G.R. No. 269159)
Background of the Case
The case arose from the enactment of RA 9019, which converted the Municipality of Malabon into a highly urbanized city. This law defined the territorial boundaries of Malabon and included portions of what had previously been the territory of Caloocan. This led to claims of constitutional violations, specifically concerning the lack of a plebiscite to alter the boundaries as stipulated by Article X, Section 10 of the Constitution.
Initial Claims and Legal Proceedings
Henry P. Cammayo, a former Caloocan council member, along with other local officials, filed a petition for declaratory relief in 2002, seeking to have RA 9019 declared unconstitutional. They argued that the territories claimed by Malabon included barangays that had historically belonged to Caloocan without the conduct of a necessary plebiscite. Cammayo's petition highlighted the historical, administrative, and legal ties that these barangays had with Caloocan.
Respondents' Counterarguments
In response, Malabon asserted that the petitioners lacked legal standing since they were not directly affected by the law. Malabon contended that their existing territorial claims remained valid and did not require a plebiscite as the areas had always been part of Malabon. Additionally, it argued that the appropriate procedure for such disputes lay within administrative channels outlined in the Local Government Code.
Findings During the Trial
Witnesses for both Caloocan and Malabon presented historical, tax, and administrative evidence regarding the territorial boundaries. The trial established that the disputed barangays had been included in Malabon’s territory under RA 9019. However, evidence was also presented that showed Caloocan’s long-standing administrative control over the same areas.
Ruling of the Regional Trial Court
The RTC ruled in favor of Caloocan in January 2019, declaring RA 9019 unconstitutional on grounds that it violated the plebiscite requirement for territorial boundary alterations. The RTC issued a permanent injunction preventing Malabon from exercising jurisdiction over the disputed barangays, establishing that the constitutional requisites had not been met.
Court of Appeals Decision
The CA reversed the RTC's decision in February 2023, stating that the case constituted a boundary dispute that should first be resolved through administrative channels specified in the Local Government Code. The CA noted that it was premature for the RTC to assume jurisdiction over the case without exhausting the prescribed administrative remedies.
Issues Presented
Caloocan's arguments before the Court hinged on the necessity of a plebiscite due to the alteration of its territorial boundaries by RA 9019. Malabon countered that declaratory relief was inappropriate since the law had already been in effect and jurisdiction had been implemented prior to the filing of the petition.
The Court’s Ruling
The Court found that the CA did not err in its ruling. It reaffirmed the principle that boundary disputes between LGUs necessitat
...continue readingCase Syllabus (G.R. No. 269159)
Background and Nature of the Case
- The case involves a Petition for Review on Certiorari filed by the City of Caloocan, assailing the Court of Appeals decision which reversed the RTC ruling that declared RA 9019, the Charter of the City of Malabon, invalid and unconstitutional.
- RA 9019 converted the Municipality of Malabon into a highly urbanized city (HUC), defining its territorial boundaries, which allegedly overlap with the territorial jurisdiction of the City of Caloocan.
- The petitioners argue that Section 2 of RA 9019 substantially altered the boundaries of Caloocan without the constitutionally required plebiscite.
Facts of the Case
- RA 9019 was enacted on March 5, 2001, converting Malabon into an HUC with defined boundaries.
- The electorate of Malabon ratified this conversion via plebiscite on April 21, 2001.
- Section 2 of RA 9019 provides specific metes and bounds of Malabon's territorial boundaries, some portions of which overlap with barangays historically under Caloocan.
- Petitioners, led by Henry P. Cammayo and others including former officials and residents of the subject barangays (160 and 161), filed a declaratory relief petition alleging unconstitutional boundary alteration without plebiscite.
- Caloocan's territorial claims are supported by past surveys, tax declarations, voter registrations, and cadastral documents.
- Malabon disputes these claims, asserting the said territories have always been under its jurisdiction and denying the need for a plebiscite.
Procedural History
- The RTC initially ruled RA 9019 unconstitutional for violating Article X, Section 10 of the Constitution regarding the plebiscite requirement and issued a permanent injunction against Malabon's jurisdiction over the subject barangays.
- Malabon sought reconsideration which was denied, then appealed to the Court of Appeals.
- The Court of Appeals reversed the RTC decision and dismissed the case without prejudice, ruling that the dispute is a boundary dispute that should be resolved through administrative remedies under Sections 118 and 119 of the Local Government Code (LGC).
- The petition for reconsideration to the CA was denied, prompting the present petition to the Supreme Court.
Issue Presented
- Whether the Court of Appeals erred in reversing the RTC ruling and dismissing the petition for declaratory relief without prejudice.
- Whether Section 2 of RA 9019 is unconstitutional for failing to observe the plebiscite requirement.
Arguments of the Parties
Pet