Title
Municipality of Pateros vs. City of Taguig
Case
G.R. No. 220824
Decision Date
Apr 19, 2023
Pateros, Taguig, and Makati dispute Fort Bonifacio boundaries; SC ruled Pateros complied with LGC, reinstated case for RTC resolution.

Case Summary (G.R. No. 90314)

Relevant Legal Framework and Background

  • The boundary conflict between Makati, Taguig, and Pateros has persisted for over 30 years, centered on areas declared part of Makati by Presidential Proclamations Nos. 2475 (1986) and 518 (1991).
  • Pateros initially filed a complaint in 1993 seeking judicial declaration of its territorial boundaries and nullification of Proclamation No. 2475, alleging a reduction of its original territory through cadastral remapping.
  • Taguig also filed a case in 1993 asserting that certain portions of Fort Bonifacio were wrongly declared part of Makati, challenging the constitutionality of said proclamations.
  • Pateros sought to intervene in Taguig’s case but was denied for procedural reasons.

Judicial Proceedings Prior to Present Case

  • The RTC of Pasig ruled in favor of Taguig declaring portions of Fort Bonifacio as Taguig’s territory, invalidating parts of Proclamations Nos. 2475 and 518 for lack of plebiscite as required by the 1987 Constitution, particularly Section 10, Article X.
  • Makati’s motions for reconsideration and petitions were denied or dismissed on procedural grounds, including being found guilty of forum shopping.
  • The Supreme Court in a related case (G.R. No. 235316) adjudicated that Taguig had a superior claim over certain disputed areas, basing the decision on preponderance of historical evidence, surveys, and government acts prior to the 1973 Constitution.
  • Pateros’ earlier case was dismissed for lack of jurisdiction since appeals on questions of law regarding territorial jurisdiction should be elevated directly to the Supreme Court under Rule 45 of the Rules of Court.

Legal Principles on Boundary Disputes Under the Local Government Code (LGC)

  • Section 118, LGC mandates that boundary disputes between LGUs must be settled amicably as far as possible, referring disputes to the proper sanggunian (local legislative bodies) depending on the LGUs involved:
    • Barangays within a city or municipality: sangguniang panlungsod or sangguniang bayan
    • Municipalities within the same province: sangguniang panlalawigan
    • Municipalities or component cities of different provinces: sanggunians of the respective provinces jointly
    • Between a component city or municipality and a highly urbanized city, or between highly urbanized cities: respective sanggunians jointly
  • If amicable settlement fails within 60 days, the sanggunian concerned must issue a certification of failure and formally try and decide the dispute within another 60 days.
  • Section 119, LGC provides for judicial appeal to the RTC as appellate jurisdiction over the sanggunian’s decision.
  • Rule III of the LGC’s Implementing Rules and Regulations (IRR) sets detailed procedures: filing petitions by resolution, furnishing copies for answers, conducting hearings, joint hearing protocols where multiple sanggunians are involved, and timelines for decisions and appeals.

Factual Summary of Present Case

  • Pateros filed an original complaint in 2012 (Civil Case No. 73387-TG) against Makati and Taguig, claiming judicial declaration over Parcel 4 of Survey Plan Psu-2031 (approximately 766 hectares), part of Fort Bonifacio.
  • Pateros supported its claim with historic maps, evidencing its original jurisdiction and continued assertion of control over the subject area.
  • Pateros sought to initiate an amicable settlement by inviting Makati and Taguig’s sanggunians for dialogue following the Supreme Court’s prior directive in G.R. No. 157714.
  • Makati cooperated partially, engaging in joint resolutions and dialogues with Pateros; Taguig ignored the requests for dialogue.
  • Pateros’ sangguniang bayan unilaterally issued certifications declaring failure of amicable settlement.
  • Makati moved to dismiss on procedural grounds, arguing non-compliance with Sections 118 and 119 of the LGC and lack of RTC jurisdiction over original boundary disputes.
  • Taguig moved to dismiss based on non-compliance with amicable settlement procedures and alleged forum shopping.

Lower Courts’ Decisions

  • The RTC of Pasig granted the motion to dismiss filed by Makati, ruling Pateros had not complied with the mandated administrative steps under the LGC and thus deprived the court of jurisdiction.
  • The CA affirmed the dismissal, emphasizing that original jurisdiction lies with the sanggunian jointly acting and that the RTC only exercises appellate jurisdiction over decisions of the sanggunian.
  • The CA noted that Pateros acted unilaterally without joint action from Makati and Taguig sanggunians, invalidating its case for non-compliance with the prescribed procedures.

Issues Presented to the Supreme Court

  1. Whether Pateros complied with the requirements for amicable settlement under Sections 118(d) and (e) of the LGC and Rule III of the IRR, as previously directed by this Court.
  2. Whether Taguig’s failure to respond to invitations for settlement justified the filing of the complaint directly in the RTC.
  3. Whether the RTC of Pasig had jurisdiction over Pateros’ original complaint (Civil Case No. 73387-TG).

Petitioner’s (Pateros) Arguments

  • Pateros asserted it exerted all reasonable efforts for amicable settlement, but Taguig and Makati refused or ignored repeated requests for dialogue, thereby frustrating compliance.
  • Pateros argued that the law does not explicitly require a joint resolution by the sanggunians before filing in court, only that disputes be referred to the respective sanggunians.
  • The Court’s prior ruling (G.R. No. 157714) directed compliance with Sections 118 and 119 “without prejudice to judicial recourse,” meaning judicial action remains available after reasonable attempts at settlement.
  • Pateros denied any forum shopping, maintaining its interventions and complaints were in furtherance of asserting its rightful claims.
  • Pateros argued that requiring strict procedural compliance by a petitioner frustrated by the refusal of other LGUs to cooperate would produce unjust and oppressive results contradicting principles of statutory construction aimed to avoid hardship.

Respondents’ Arguments

  • Taguig contended the petition was defective for non-payment of fees and lack of authority of the signatory but mainly argued for dismissal on non-compliance with the amicable settlement procedure.
  • Taguig maintained that Pateros’ resolutions were unilateral requests for dialogue, failing to satisfy the requirement for joint action and formal petitions before the sanggunians, and that Pateros was guilty of forum shopping by filing multiple suits.
  • Makati argued the RTC lacked jurisdiction over the original boundary dispute and that Pateros failed to comply with mandatory procedural steps, including seeking joint settlement by the respective sanggunians.
  • Both respondents held that under the LGC, the RTC only has appellate jurisdiction to entertain appeals from the sanggunians’ decisions and cannot hear original boundary disputes.

Supreme Court’s Ruling

  • The Court granted the petition, reversing and setting aside the CA decision and RTC resolution, and directing the RTC of Pasig to reinstate the civil case.
  • The Court reaffirmed the principle that boundary disputes between LGUs must be resolved amicably and jointly by respective sanggunians as mandated by Sections 118 and 119 of the LGC and Rule III of its IRR.
  • However, the Court held that compliance with these procedural requirements presupposes the cooperation of all parties. Where a party refuses to participate or respond, it effectively makes amicable settlement impossible.
  • The failure of Taguig to respond to multiple invitations for dialogue justified Patero
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