Case Summary (G.R. No. 141375)
Context and Nature of the Case
This case involves a boundary dispute between the Municipality of Kananga and the City of Ormoc, an independent component city. The parties initially attempted to settle their dispute amicably through a joint session of their respective local legislative bodies, the Sangguniang Bayan of Kananga and the Sangguniang Panlungsod of Ormoc City, but failed to reach a settlement. Consequently, the City of Ormoc filed a complaint before the RTC of Ormoc City (Branch 35) seeking judicial resolution. The Municipality of Kananga moved to dismiss the complaint, asserting lack of jurisdiction and failure to comply with conditions precedent under the law.
Summary of Facts and Procedural History
On October 31, 1997, a joint session of the local sanggunian of Kananga and Ormoc was held specifically for amicable settlement of the boundary dispute, per Section 118 of the Local Government Code. The session resulted in Resolution No. 97-01, certifying the failure of amicable settlement and agreeing to elevate the dispute to the courts. On September 2, 1999, Ormoc City filed Civil Case No. 3722-O before RTC Branch 35 seeking adjudication of the boundary dispute. Kananga filed a Motion to Dismiss on September 24, 1999, raising the grounds of lack of jurisdiction, absence of cause of action, and non-compliance with required preconditions.
Ruling of the Regional Trial Court and Grounds
The RTC denied the Motion to Dismiss. It ruled that it possessed jurisdiction under Batas Pambansa Blg. 129 and that the parties substantially complied with Section 118 of the Local Government Code by going through a joint session and agreement to bring the case to court. The RTC further explained that Section 118 governs venue, which can be waived or agreed upon by the parties, and was not a strict jurisdictional bar.
Legal Issue Presented to the Supreme Court
The primary legal issue addressed is whether the Regional Trial Court may exercise original jurisdiction over a boundary dispute between a municipality and an independent component city, given the absence of explicit statutory provisions conferring such jurisdiction.
Jurisdiction as a Matter of Law
The Supreme Court emphasized that jurisdiction is a question of law rooted in substantive law vested by statute. Jurisdiction cannot be conferred by parties' consent and must be based on existing laws at the time the action is commenced. Both parties recognized that Section 118 of the Local Government Code, effective January 1, 1992, was the governing statute concerning boundary dispute settlement procedures between local government units.
Scope and Limits of Section 118 of the Local Government Code
Section 118 categorizes boundary disputes depending on the local government units involved—barangays, municipalities, component cities, highly urbanized cities, and provinces—and prescribes the appropriate sanggunian venues for amicable settlement. Critically, disputes between a municipality or component city and a highly urbanized city fall under the sanggunians’ joint settlement process.
Distinction Between Independent Component City and Highly Urbanized City
Kananga is a municipality per Republic Act No. 542. Ormoc City, created under Republic Act No. 179 and defined under the Local Government Code, is an independent component city, not a highly urbanized city. Ormoc City’s charter prohibits its voters from electing provincial officials, which confirms its classification as an independent component city—a status recognized in Batas Pambansa Blg. 643 and the Omnibus Election Code. There is no claim nor presidential declaration categorizing Ormoc as highly urbanized.
Applicability of Section 118 to the Present Case
Section 118 of the Local Government Code applies specifically to disputes involving highly urbanized cities. Since Ormoc is an independent component city, and not highly urbanized, the procedural mechanism under Section 118 does not apply strictly to the dispute between Kananga and Ormoc. Despite this, the parties went through a joint session and agreed to submit their dispute to the RTC, after failing to reach amicable settlement.
Authority of the Regional Trial Court Over the Dispute
In the absence of a specific law granting exclusive jurisdiction, the Court found that the RTC possessed general original jurisdiction over the case pursuant to Batas Pambansa Blg. 129, Section 19(6), which vests RTCs with exclusive original jurisdiction over all civil cases not specially assigned by law to other courts or tribunals. Jurisdiction, therefore, exists by force of law, not by party consent or agreement.
Jurisdiction vs. Venue
The Court clarified that jurisdiction is distinct from venue.
...continue readingCase Syllabus (G.R. No. 141375)
Nature of the Case and Petition
- This case involves a Petition for Certiorari under Rule 65 of the Rules of Court.
- The petition seeks to annul the October 29, 1999 Order of the Regional Trial Court (RTC) of Ormoc City (Branch 35) in Civil Case No. 3722-O.
- The RTC had denied the Municipality of Kananga’s motion to dismiss a boundary dispute complaint filed by the City of Ormoc.
- The issue concerns the jurisdiction of the RTC to hear and determine a boundary dispute between a municipality and an independent component city.
- The Court ruled that since no specific law governs jurisdiction over such disputes, the RTC has power and authority to adjudicate.
Factual Background of the Boundary Dispute
- The boundary dispute arose between the Municipality of Kananga and the City of Ormoc, both in the province of Leyte.
- Both parties agreed initially to an amicable settlement via a joint session of their respective sanggunians (local legislative councils) on October 31, 1997.
- The joint session failed to reach an amicable settlement, issuing Resolution No. 97-01, certifying their failure and agreeing to elevate the dispute to the proper court.
- Consequent to the resolution, the City of Ormoc filed a civil complaint before the RTC of Ormoc City on September 2, 1999.
- The Municipality of Kananga filed a motion to dismiss on grounds of lack of jurisdiction, lack of cause of action, and non-compliance with a prerequisite condition.
- The RTC denied the motion to dismiss, holding that it had jurisdiction under Batas Pambansa Blg. 129 and that procedural requirements under the Local Government Code were substantially complied with.
Legal Issue Presented
- The sole legal issue: Whether the Regional Trial Court possesses original jurisdiction over a boundary dispute between a municipality and an independent component city.
- Both parties addressed and debated the applicability of Section 118 of the Local Government Code (LGC) regarding jurisdictional rules for boundary disputes.
- The Court examined the nature and classification of the local government units involved—Kananga as a municipality and Ormoc as an independent component city.
Governing Statutory Provisions on Jurisdiction
- Section 118 of the 1991 Local Government Code governs boundary disputes among local government units, emphasizing amicable settlement by respective sanggunians.
- The provision distinguishes jurisdiction based on the classification of local government units:
- Barangays within same city or municipality.
- Municipalities within same provin