Title
City of Caloocan vs. City of Malabon
Case
G.R. No. 269159
Decision Date
Nov 4, 2024
Caloocan challenged the constitutionality of RA 9019, asserting it altered boundaries without a plebiscite. The CA overturned the RTC's ruling, deeming a proper administrative route necessary before judicial action.
boundary dispute
declaratory relief
local government units

Case Summary (G.R. No. 269159)

Factual Background

On March 5, 2001, RA 9019 converted the Municipality of Malabon into a highly urbanized city and defined its boundaries by explicit metes and bounds and geographic coordinates. The plebiscite to ratify the conversion took place on April 21, 2001. Petitioners alleged that Section 2 of RA 9019 included within Malabon portions of Barangays 160 and 161 (Libis, Baesa) that historically belonged to Caloocan. Petitioners claimed that those barangays comprised some thirty-seven hectares with roughly nine thousand registered voters who had voted in Caloocan elections since 1961. Petitioners further alleged that no plebiscite was conducted in those barangays to effect any change in their territorial status as required by Article X, Section 10 of the Constitution and by the Local Government Code.

Procedural Posture Before the RTC

On September 10, 2002, Henry P. Cammayo and former barangay officials of Barangays 160 and 161 filed a Petition for declaratory relief with prayer for preliminary injunction against City of Malabon, its Mayor, Vice Mayor, and Sangguniang Panlungsod members. The Republic of the Philippines was later impleaded and the Court issued a preliminary injunction on October 10, 2002. The City of Caloocan intervened on July 15, 2004, alleging that Section 2 of RA 9019 violated Article X, Section 10 of the Constitution by altering Caloocan’s boundaries without a plebiscite. The parties proceeded to trial and presented documentary and testimonial evidence concerning historical surveys, cadastral plans, tax declarations, voter lists, and cadastral certifications.

Trial Court Proceedings and Evidence

Petitioners and intervenor Caloocan presented witnesses who testified to historical inclusion of the subject barangays within Caloocan, the issuance of land titles and tax declarations by Caloocan authorities, and the absence of any COMELEC record of a plebiscite conducted in the subject barangays. Malabon countered with testimony and documentary evidence that its territorial limits as described in RA 9019 corresponded to technical mappings and cadastral surveys predating RA 9019, including NAMRIA maps, cadastral plans, and certification by DENR personnel. Both sides relied on historical maps, cadastral surveys, and administrative acts to support competing claims of jurisdiction over the same territory.

Ruling of the Regional Trial Court

The RTC, in a Decision dated January 28, 2019, declared RA 9019 invalid, unconstitutional, and of no force and effect. The RTC held that Section 2 of RA 9019 substantially altered the territorial jurisdiction of Caloocan by including portions of Barangays 160 and 161 without conducting a plebiscite in those barangays as required by Article X, Section 10 of the Constitution and by the Local Government Code. The RTC made permanent the preliminary injunction enjoining Malabon from exercising jurisdiction over the contested areas.

Proceedings in the Court of Appeals

Malabon appealed. The Court of Appeals, in its Decision of February 28, 2023, reversed and set aside the RTC Decision and dismissed the case without prejudice. The CA concluded that the controversy was essentially a boundary dispute between two highly urbanized cities that should have been jointly referred for amicable settlement to their respective Sanggunians pursuant to Section 118(d) of the Local Government Code of 1991 and the IRR, Rule III, Article 17. The CA held that the RTC had prematurely assumed jurisdiction and that the administrative remedy under Sections 118 and 119 of the LGC must be exhausted before resort to judicial intervention.

Issue Presented to the Supreme Court

The sole issue presented to the Supreme Court was whether the Court of Appeals erred in reversing the RTC and dismissing the Petition for declaratory relief without prejudice. More specifically, the question was whether Caloocan’s challenge to the constitutionality of Section 2 of RA 9019 could be properly entertained as a petition for declaratory relief, or whether the controversy was a boundary dispute subject to the amicable settlement and administrative procedures prescribed by the Local Government Code of 1991.

Parties’ Contentions

Caloocan argued that Section 2 of RA 9019 was unconstitutional for failing to require a plebiscite in the barangays directly affected by the alteration of boundaries under Article X, Section 10 of the Constitution. Caloocan emphasized the absence of any COMELEC record of a plebiscite in Barangays 160 and 161 and maintained that declaratory relief was appropriate to secure a judicial declaration of the statute’s invalidity. Malabon contended that a petition for declaratory relief was improper because the statute had already been in effect and Malabon had already exercised authority over the contested territory. Malabon also asserted that the contested areas had historically lain within Malabon’s technical boundaries and that Sections 118 and 119 of the LGC required joint referral of boundary disputes to the parties’ Sanggunians before judicial relief.

Supreme Court’s Disposition

The Supreme Court denied the Petition for review on certiorari and affirmed the Court of Appeals’ Decision and Resolution. The Court held that the core controversy was a boundary dispute between two highly urbanized cities and that the statutory procedure under Sections 118 and 119 of the Local Government Code of 1991 and Rule III of its Implementing Rules and Regulations applies. The Court directed the parties to comply with Section 118(d) and (e) of the LGC and the IRR, Rule III, without prejudice to judicial recourse thereafter.

Legal Basis and Reasoning

The Court reasoned that both Caloocan and Malabon asserted competing claims of jurisdiction over the same areas of Barangays 160 and 161 based on historical surveys, cadastral plans, and administrative acts. Such competing claims, the Court explained, by definition constitute a boundary dispute under Rule III, Article 15 of the IRR of the LGC because a portion of the territorial area is claimed by two LGUs. The Court emphasized the mandatory procedural scheme in the LGC: boundary disputes involving two highly urbanized cities must first be jointly referred to their respective Sanggunians for amicable settlement under Section 118(d). If the sanggunian fails to settle the dispute within sixty days, it must issue a certification and formally try the dispute within sixty days. Only after these intermediary steps may a party elevate the decision to the proper Regional Trial Court under Sec

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