Title
Municipality of Bakun, Benguet vs. Municipality of Sugpon, Ilocos Sur
Case
G.R. No. 241370
Decision Date
Apr 20, 2022
Boundary dispute between Bakun, Benguet, and Sugpon, Ilocos Sur over 1,117.20 hectares; SC upheld CA/RTC ruling favoring Sugpon based on evidence, rejecting Bakun's reliance on vague laws.
boundary dispute
preponderance of evidence
resolution
A

Case Summary (G.R. No. 241370)

Factual Background

Municipality of Sugpon, Ilocos Sur and Municipality of Bakun, Benguet disputed possession and jurisdiction over a 1,117.20-hectare area comprised of barangays and sitios identified in the record as parts of Banga, Caoayan, and Danac in Sugpon. The controversy arose from competing claims of territorial jurisdiction and from certificates of land ownership awards and local acts of administration over the area.

Proceedings Before the Sangguniang Panlalawigan

A joint committee of the Sangguniang Panlalawigan of Ilocos Sur and Benguet investigated the dispute and, on May 12, 2014, adopted Joint Resolution No. 1, Series of 2014, adjudicating the disputed area to Municipality of Bakun, Benguet. Municipality of Sugpon, Ilocos Sur appealed the joint resolution to the Regional Trial Court.

Trial Court Proceedings

The Regional Trial Court, in a Resolution dated April 28, 2015, set aside Joint Resolution No. 1, Series of 2014 and adjudicated the 1,117.20 hectares to Municipality of Sugpon, Ilocos Sur. The RTC found that Act Nos. 1646 and 2877 did not provide specific metes and bounds for the municipalities and therefore could not support Bakun’s claim of a better right. The RTC gave greater weight to Sugpon’s documentary evidence, including maps and public instruments, and concluded Sugpon’s evidence was more persuasive than Bakun’s.

Court of Appeals Proceedings

Municipality of Bakun sought recourse with the Court of Appeals. In a Decision dated February 1, 2018, the CA denied the petition and affirmed the RTC in toto. The CA held that the dispute was a boundary question to be decided by a preponderance of evidence and found Sugpon’s maps, certifications, tax declarations, school jurisdiction documents, ancestral domain certification, and evidence of local governance activities sufficient to establish territorial jurisdiction. The CA also concluded that Act Nos. 1646 and 2877 were too vague to establish exact municipal boundaries between Bakun and Sugpon.

Issues Presented

The primary issue presented to the Supreme Court was whether the CA and the RTC erred in adjudicating the 1,117.20 hectares to Municipality of Sugpon, Ilocos Sur, particularly whether Act Nos. 1646 and 2877 established the boundary in favor of Municipality of Bakun, Benguet, and whether the lower courts misweighed the evidence.

Parties' Contentions

Municipality of Bakun contended that it presented the greater weight of evidence that the disputed area belonged to Bakun and that Act Nos. 1646 and 2877 already defined the boundary separating Bakun and Sugpon. Bakun also argued that Sugpon’s documentary proofs—maps, certifications, and petitions of residents and elders—were inconclusive and should not be afforded weight. Municipality of Sugpon replied that the petition raised factual issues beyond the scope of a Rule 45 petition and that the CA correctly found Sugpon’s evidence sufficient to establish territorial jurisdiction.

Standard of Review

The Supreme Court observed that a petition for review on certiorari under Rule 45, Rules of Court ordinarily raises questions of law only. The Court reiterated the limited exceptions that permit review of factual findings, which require a showing that the case falls within recognized grounds such as findings grounded entirely on speculation, manifestly mistaken inferences, grave abuse of discretion, misapprehension of facts, or conflicting findings, among others.

Supreme Court Ruling

The Supreme Court denied the petition. It held that the exceptions to the Rule 45 limitation were not established and that the CA and RTC findings of fact were supported by the record. The Court affirmed the CA’s decision upholding the RTC’s adjudication of the disputed 1,117.20 hectares to Municipality of Sugpon, Ilocos Sur.

Legal Basis and Reasoning

The Court found multiple, credible, and unrebutted documentary proofs in favor of Municipality of Sugpon. These included the Administrative Map of Benguet showing the disputed area within Sugpon’s territory; Land Classification Maps Nos. 3441 and 1298; the Topographic and Administrative Map of Ilocos Sur; a Department of Environment and Natural Resources certification; a Department of Agrarian Reform certification; tax declarations and a Master List of Tax Declarations certified by Sugpon’s Municipal Assessor; the Schools Division Superintendent’s certification that Nagawa Elementary School fell under the Division of Ilocos Sur; testimony of a pioneer teacher; election documents showing established voting centers and registered voters of Sugpon; and a Certificate of Ancestral Domain Title and petitions of residents and elders asserting historical occupation by Sugpon’s indigenous people. The Court treated these public instruments as presumptively regular and reliable for delineating territorial extent in the absence of evidence of falsity.

The Court analyzed Act Nos. 1646 and 2877 and related historical legislation and concluded that those enactments did not categorically delineate the metes and bounds of the municipalities of Bakun and Sugpon. The Court reproduced and considered Section 1 of Act No. 2877 and agreed with the RTC that the statutory language was broad and did not mention Benguet or specifically fix municipal boundaries between Bakun and Sugpon. The Court noted that Bakun’

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