G.R. No. 125646 - City of Pasig vs. Commission on Elections

Case Summary (G.R. No. 125646)

Key Individuals and Context

Petitioners: City of Pasig (G.R. No. 125646); Municipality of Cainta, Province of Rizal (G.R. No. 128663).
Respondents: Commission on Elections (COMELEC); the opposing local government unit (each petition involves the other municipality/city as adversary regarding territorial claims).
Disputed localities: proposed Barangays Karangalan and Napico, areas claimed by both the City of Pasig and the Municipality of Cainta.
Core factual nexus: both petitions challenge COMELEC action (or inaction) to suspend, cancel or allow plebiscites creating the two barangays while a separate civil action for boundary delineation between the two local government units (Civil Case No. 94-3006, RTC, Antipolo) remained pending.

Key Dates (pertinent events)

Ordinance creating Barangay Karangalan (City of Pasig): April 22, 1996; plebiscite scheduled June 22, 1996.
Ordinance creating Barangay Napico (City of Pasig): September 9, 1996; plebiscite held March 15, 1997.
COMELEC petitions filed by Municipality of Cainta to suspend/cancel plebiscites: June 19, 1996 (UND No. 96-016) for Karangalan; March 12, 1997 (UND No. 97-002) for Napico.

Applicable Law and Precedents

Constitution: 1987 Constitution (applicable because the decision was rendered in 1999).
Statutory provision: Section 386(b), R.A. No. 7160 (Local Government Code) — requires territorial jurisdiction of a barangay to be identified by metes and bounds or by more or less permanent natural boundaries for creation of barangays.
Controlling precedents cited: Vidad v. RTC of Negros Oriental, Br. 42 (prejudicial question doctrine); Mariano, Jr. v. Commission on Elections (importance of precise territorial boundaries for local government units); Tan v. Commission on Elections (rejection of mootness/academic dismissal where constitutionality or legality of plebiscite is challenged despite a fait accompli).

Procedural history

Municipality of Cainta filed petitions with COMELEC seeking suspension or cancellation of the scheduled plebiscites on grounds that the areas involved were included within a pending boundary dispute in RTC Antipolo (Civil Case No. 94-3006).
COMELEC issued differing rulings: UND No. 96-016 placed the Karangalan plebiscite in abeyance pending final adjudication of the boundary dispute; UND No. 97-002 dismissed Cainta’s petition regarding Napico as moot because the plebiscite had been held and Napico’s creation ratified.
Two petitions to the Supreme Court ensued: City of Pasig sought review of COMELEC’s suspension in G.R. No. 125646; Municipality of Cainta sought review of COMELEC’s dismissal and validation of the Napico plebiscite in G.R. No. 128663.

Issue presented

Whether COMELEC properly suspended or cancelled (or refused to suspend) the plebiscites creating Barangays Karangalan and Napico pending resolution of the pending boundary dispute between the City of Pasig and the Municipality of Cainta.

Supremes’ legal analysis — prejudicial question doctrine and interrelationship of actions

The Court found that the pending civil action for boundary determination (Civil Case No. 94-3006) presented a prejudicial question that must be resolved before the plebiscites could validly proceed. The prejudicial question doctrine permits suspension of action in one proceeding when its outcome materially depends on or is closely interrelated with the outcome of another pending case.
Although the City of Pasig argued that the prejudicial question doctrine is inapplicable where both cases are civil, the Court noted precedent (Vidad) permitting suspension where one case’s final determination would have material bearing on the other; here the territorial jurisdiction question raised in the RTC action directly affects whether the areas fall within Pasig or Cainta and thus whether the creation of new barangays by Pasig is valid.

Territorial delineation requirement for barangay creation

The Court emphasized statutory and jurisprudential rules requiring precise delineation of territorial jurisdiction (metes and bounds or permanent natural boundaries) as a prerequisite to creating a local government unit. The Court quoted and relied on earlier decisions underscoring that clear boundaries define the limits of a local government’s lawful exercise of power and that uncertainty invites ultra vires acts and conflicts prejudicial to the public welfare.
Because portions of the areas subject to the proposed barangays were part of the pending boundary dispute, any attempt to define the barangays’ territorial jurisdiction prior to final resolution of the civil action would be premature and potentially futile.

On the mootness argument and the Napico plebiscite

The City of Pasig contended that the Napico matter was moot because the plebiscite had already been conducted and approval obtained. The Court rejected dismissal on grounds of mootness, citing Tan v. COMELEC: where the legality of a plebiscite is challenged for non-compliance with constitutional requisites, the mere occurrence of a plebiscite and a resulting fait accompli do not render judicial inquiry improper. Permitting finality by fait accompli would invite circumvention of legal requirements and offend public interest.
Accordingly, the Court held that the plebiscite ratifying the creation of Barangay Napico, even though already held, could be annulled if the proceeding was tainted by unresolved territorial disputes that are determinative of jurisdictional competence.

Disposition and relief granted

G.R. No. 125646 (City of Pasig): Petition dismissed for lack of merit. The COMELEC order that had placed the Karangalan plebiscite in abeyance was sustained in effect; the Karangalan plebiscite must remain held in abeyance

Case Syllabus (G.R. No. 125646)

Case Caption and Nature of Proceedings

Two consolidated petitions were before the Supreme Court en banc, arising from separate but related proceedings concerning the creation of two proposed barangays in the City of Pasig: Barangay Karangalan and Barangay Napico.
G.R. No. 125646: City of Pasig as petitioner versus the Commission on Elections (COMELEC) and the Municipality of Cainta, Province of Rizal, as respondents; this petition challenges COMELEC’s order holding the plebiscite for Barangay Karangalan in abeyance.
G.R. No. 128663: Municipality of Cainta, Province of Rizal, as petitioner versus the COMELEC and City of Pasig, respondent; this petition challenges COMELEC’s dismissal of Cainta’s petition regarding the plebiscite for Barangay Napico as moot after the plebiscite had been held and ratified.
Decision rendered September 10, 1999, reported at 372 Phil. 864, by Justice Ynares-Santiago writing for the Court.

Antecedent Facts

On April 22, 1996, residents of Karangalan Village petitioned to segregate from Barangays Manggahan and Dela Paz, City of Pasig, to form a distinct barangay to be named Barangay Karangalan.
The City Council of Pasig enacted Ordinance No. 21, Series of 1996, creating Barangay Karangalan; a plebiscite was scheduled for June 22, 1996. (Petition, G.R. No. 125646, Annex aAa, Rollo, pp. 23–25.)
On September 9, 1996, the City of Pasig enacted Ordinance No. 52, Series of 1996, creating Barangay Napico; a plebiscite was scheduled for March 15, 1997. (Petition, G.R. No. 128663, Annex, Rollo, pp. 37–39.)
Upon learning of the ordinances and scheduled plebiscites, the Municipality of Cainta moved to suspend or cancel those plebiscites and filed petitions with COMELEC: UND No. 96-016 (filed June 19, 1996) for Karangalan, and UND No. 97-002 (filed March 12, 1997) for Napico. (Petition, G.R. No. 125646, Annex aBa, Rollo, pp. 26–31.)
Cainta alerted COMELEC to a pending civil case, Civil Case No. 94-3006, before the Regional Trial Court (RTC) of Antipolo, Rizal, Branch 74, which concerned the boundary dispute between Cainta and Pasig; Cainta asserted that portions of the proposed barangays were included in that pending boundary dispute. (Petition, G.R. No. 125646, Annex aQa, Civil Case No. 94-3006, Rollo, pp. 170–177; Petition, G.R. No. 128663, Annex aJa, Rollo, pp. 42–45.)

COMELEC Actions and Divergent Dispositions

In UND No. 96-016 (concerning Barangay Karangalan), COMELEC accepted Cainta’s position and ordered the plebiscite to be held in abeyance until the RTC finally resolved the boundary dispute. (See Petition, G.R. No. 125646, Annex aDa, Order, UND No. 96-016, Rollo, pp. 35–36.)
In UND No. 97-002 (concerning Barangay Napico), COMELEC dismissed Cainta’s petition as moot because the plebiscite had been held on March 15, 1997 and the creation of Barangay Napico was ratified by a majority of votes cast. (See Petition, G.R. No. 128663, Annex aMa, Order, UND No. 97-002, Rollo, pp. 67–68.)
The divergent COMELEC rulings prompted the two petitions to the Supreme Court: Pasig’s challenge to the abeyance order (G.R. No. 125646) and Cainta’s challenge to the dismissal and the plebiscite’s ratification (G.R. No. 128663).

Principal Issue Presented

Whether the plebiscites scheduled for the creation of Barangays Karangalan and Napico should be suspended, canceled, or set aside in view of the pending boundary dispute between the Municipality of Cainta and the City of Pasig (Civil Case No. 94-3006, RTC Antipolo).

Court’s Holding / Disposition

The Supreme Court held that the pending civil case over boundaries constitutes a prejudicial question that must first be decided before plebiscites for the creation of the proposed barangays may be validly held.
G.R. No. 125646 (City of Pasig): Petition dismissed for lack of merit; the COMELEC order placing the plebiscite for Barangay Karangalan in abeyance is sustained.
G.R. No. 128663 (Municipality of Cainta): Petition granted. The COMELEC Order UND No. 97-002 dated March 21, 1997 is set aside; the plebiscite held on March 15, 1997 that ratified the creation of Barangay Napico is declared null and void.
Both plebiscites (Karangalan and Napico) are ordered to be held in abeyance until after final resolution of the boundary dispute by the RTC in Civil Case No. 94-3006.
No pronouncement as to costs.
Judgment concurred in by Justices Bellosillo, Melo, Puno, Vitug, Kapunan, Mendoza, Panganiban, Quisumbing, Purisima, Buena, and Gonzaga-Reyes; Chief Justice Davide, Jr. was on official leave; Justice Pardo took no part as he was COMELEC Chairman.

Reasoning of the Court

The Court agreed with COMELEC’s determination in UND No. 96-016 that the pending RTC boundary case p