Case Summary (G.R. No. 125646)
Background and Ordinance Enactments
Pasig City, acting on petitions by residents, enacted:
- Ordinance No. 21 (Series 1996) segregating Karangalan Village from Barangays Manggahan and Dela Paz, setting a June 22 plebiscite.
- Ordinance No. 52 (Series 1996) creating Barangay Napico, setting a March 15 plebiscite.
COMELEC Petitions by Cainta and Initial Orders
Upon learning of these ordinances, Cainta filed before COMELEC:
- UND No. 96-016 (June 19, 1996) to suspend Karangalan plebiscite, citing the pending RTC boundary case.
- UND No. 97-002 (March 12, 1997) to suspend Napico plebiscite on similar grounds.
COMELEC’s rulings: - UND No. 96-016: Plebiscite on Barangay Karangalan held in abeyance.
- UND No. 97-002: Petition dismissed as moot after the March 15 plebiscite ratified Napico.
Issue Presented
Whether the plebiscites for creating Barangays Karangalan and Napico must be suspended or canceled pending final resolution of the boundary dispute between Cainta and Pasig.
Prejudicial Question Doctrine and Jurisdictional Link
The Court affirmed that the pending civil action over territorial boundaries (Civil Case No. 94-3006) raises a prejudicial question. Citing Vidad v. RTC of Negros Oriental, the suspension of administrative actions is proper when a closely related case can directly affect the outcome. Since portions of Karangalan and Napico fall within the disputed area, defining their territorial limits before judicial resolution would be futile.
Requirement of Clear Territorial Boundaries
Under Sec. 386(b) of the Local Government Code, a new barangay’s boundaries must be precisely identified. Judicial precedents (Mariano v. COMELEC) stress that local government units can only exercise powers within their clearly defined jurisdiction; ambiguity leads to ultra vires acts and conflicts.
Mootness Argument Rejected
The contention that the Napico plebiscite is now moot was rejected based on Tan v. COMELEC, which held that constitutional challenges to a plebiscite’s legality cannot be extinguished by a fait accompli. The Court will not allow an alleged illegal cre
Case Syllabus (G.R. No. 125646)
Procedural History
- Two petitions docketed as G.R. No. 125646 and G.R. No. 128663, both decided September 10, 1999 by the Supreme Court En Banc.
- G.R. No. 125646 filed by City of Pasig challenging COMELEC’s order suspending the plebiscite for Barangay Karangalan.
- G.R. No. 128663 filed by Municipality of Cainta challenging COMELEC’s dismissal of its petition to cancel the plebiscite for Barangay Napico.
- Both petitions arose from COMELEC orders in UND No. 96-016 (June 19, 1996) and UND No. 97-002 (March 12, 1997), respectively.
- The Supreme Court consolidated the issues concerning suspension or annulment of plebiscite proceedings pending resolution of a boundary dispute.
Antecedent Facts
- Residents of Karangalan Village petitioned to form Barangay Karangalan, segregating from Barangays Manggahan and Dela Paz in Pasig City.
- Pasig City Council enacted Ordinance No. 21, Series 1996 on April 22, 1996, creating Barangay Karangalan; plebiscite set for June 22, 1996.
- Pasig City Council enacted Ordinance No. 52, Series 1996 on September 9, 1996, creating Barangay Napico; plebiscite set for March 15, 1997.
- Municipality of Cainta moved to suspend or cancel both plebiscites, citing a pending boundary dispute case (Civil Case No. 94-3006) before the RTC of Antipolo, Rizal, Branch 74.
- Cainta’s petitions argued that the proposed barangay areas overlapped territory in dispute; sought COMELEC intervention to suspend plebiscite until final resolution.
Issues Presented
- Whether plebiscite proceedings for Barangays K