G.R. No. 220824 - Municipality of Pateros vs. City of Taguig

Case Summary (G.R. No. 220824)

Factual Background

The dispute concerns portions of the former Fort William McKinley (now Fort Bonifacio), comprising Barangays Cembo, South Cembo, West Rembo, East Rembo, Comembo, Pembo, Pitogo, and Bonifacio Global City. Presidential Proc. Nos. 2475 and 518 were issued in 1986 and 1991 declaring those areas part of Makati. Pateros alleges an historical claim to Parcel 4, Psu-2031, asserting prolonged exercise of jurisdiction and the diminution of its original territory after cadastral mapping. Taguig likewise asserted competing claims, and Makati asserted territorial title based on cadastral surveys and Philippine cadastral approvals.

Prior Litigation and Relevant Decisions

Taguig filed Civil Case No. 63896 before RTC Pasig, Branch 153 in 1993; the RTC ruled for Taguig on July 8, 2011, declaring Proc. Nos. 2475 and 518 unconstitutional insofar as they altered Taguig’s boundaries without plebiscite. Makati appealed, and the CA in CA-G.R. CV No. 98377 reversed on July 30, 2013. The controversy over Parcels 3 and 4 later reached this Court in G.R. No. 235316, where the Supreme Court, after addressing forum and procedure issues, held that Taguig presented the more convincing evidence and declared Taguig’s superior claim. Separately, Pateros filed Civil Case No. 93-4529 in 1993 against Makati and others; the RTC Makati dismissed for lack of jurisdiction and the CA affirmed. This Court denied Pateros’ Rule 45 petition in G.R. No. 157714 but, in the interest of justice, directed the parties to comply with Sec. 118(d) and (e) of the LGC and Rule III of the IRR, “without prejudice to judicial recourse.”

Administrative Efforts to Settle under the LGC

Following G.R. No. 157714, the Pateros Sangguniang Bayan passed Resolution No. 11-2009 requesting joint dialogue with the Makati Sanggunian. Makati accepted and met twice. The Makati and Pateros sanggunian executed a Joint Resolution on November 23, 2009 proposing that Pateros invite the Taguig Sanggunian to a tripartite dialogue. Taguig did not respond. Pateros passed successive resolutions certifying failure to reach an amicable settlement and asserting that the Taguig Sanggunian ignored repeated invitations. Pateros ultimately filed Civil Case No. 11-421 in RTC Makati on May 10, 2011, which it later moved to dismiss without prejudice in view of parallel proceedings; that motion was granted.

The Present Complaint and Pleadings

On March 27, 2012, Pateros filed Civil Case No. 73387-TG before RTC Pasig, Branch 271, seeking judicial declaration that Parcel 4, Psu-2031 (about 766.0028 ha.) lies within Pateros, and prayed for nullification of the presidential proclamations and accounting for proceeds collected by respondents while exercising jurisdiction. Taguig moved to dismiss, alleging failure to comply with anti–forum shopping rules and to pay proper filing fees. Makati answered and raised special and affirmative defenses, asserting lack of jurisdiction because Pateros did not comply with Sec. 118 and the IRR; Makati urged dismissal or suspension pending finality of the Taguig–Makati litigation.

RTC Pasig Ruling

The RTC Pasig, Branch 271 issued a Resolution on May 10, 2013 granting Makati’s motion to dismiss. The RTC found that Pateros had not followed the LGC and Rule III IRR requirements. The RTC held that Pateros failed to effect a joint referral to the respective sanggunians and did not present the composition of a joint hearing body, answers by offended LGUs, joint hearings, or a decision by the joint sanggunian as required by Arts. 16 and 17 of Rule III. The RTC therefore concluded that it lacked jurisdiction, and that resort to the RTC was appropriate only after exhaustion of the statutory administrative steps.

Court of Appeals Ruling

On appeal, the CA dismissed Pateros’ appeal in CA-G.R. CV No. 101512. The CA interpreted Sec. 118 as vesting original jurisdiction in the sanggunian concerned, which, for disputes involving a component municipality and a highly urbanized city, means the respective sanggunians jointly. The CA found that Pateros acted unilaterally in issuing its resolutions and certifications and that no joint decision by the sanggunian concerned had been rendered. The CA therefore affirmed dismissal for lack of jurisdiction.

Issues Presented to the Supreme Court

The Supreme Court framed three issues: (1) whether Pateros complied with Secs. 118(d) and (e) of the LGC and Rule III of the IRR as directed by G.R. No. 157714; (2) whether the Taguig Sanggunian’s failure to respond justified filing Civil Case No. 73387-TG against both Taguig and Makati; and (3) whether RTC Pasig, Branch 271 had jurisdiction over Civil Case No. 73387-TG.

Parties’ Principal Contentions

Pateros argued that it exerted all reasonable efforts to secure sanggunian-to-sanggunian dialogue and that Taguig and Makati refused or ignored such overtures. Pateros contended that Sec. 118 does not require a joint resolution and that the Court’s directive in G.R. No. 157714 permitting judicial recourse entitled it to file suit after substantial compliance and after the other parties frustrated the statutory procedure. Taguig countered that the petition was procedurally defective for nonpayment of fees and lack of documentary attachments and that Pateros did not comply with the LGC and IRR; Taguig further invoked forum shopping and contended that it was not bound by G.R. No. 157714. Makati maintained that the RTC lacked jurisdiction because the sanggunian procedure remained uncompleted and any judgment by the RTC as an original tribunal would be null.

The Supreme Court’s Analysis of the Statutory Scheme

The Court reiterated that Secs. 118 and 119 of the LGC and Rule III of the IRR place primary, original jurisdiction over boundary disputes with LGUs in the respective sanggunians, to be exercised jointly where a highly urbanized city and a component city or municipality are involved. The Court observed that the LGC aims to promote amicable settlement through sanggunian action and that the “sanggunian concerned” in disputes among multiple LGUs is the joint body composed of the respective sanggunians.

Application of the Statute to the Facts

The Court found that Pateros did initiate the statutory process and that Makati initially engaged in dialogue. Taguig’s silence and inaction, however, effectively frustrated a joint sanggunian process. The Court concluded that Pateros’ unilateral certification and filing were not the norm under the LGC, but that the statutory procedure is premised on consent and participation by all contested LGUs. Where an LGU’s refusal makes the sanggunian procedure impossible to complete, strict insistence on exhaustion would leave the initiating LGU without remedy.

Precedent Supporting Judicial Recourse

Relying on Province of Antique v. Judge Calabocal, the Court held that an LGU that has followed the statutory steps but is blocked by the other party’s refusal may proceed to the courts. The Court analogized the Taguig refusal to the explicit refusal in Province of Antique, and concluded that Pateros’ resort to the RTC was warranted under the circumstances. The Cou

Case Syllabus (G.R. No. 220824)

Parties and Procedural Posture

Municipality of Pateros filed Civil Case No. 73387-TG in the Regional Trial Court of Pasig, Branch 271, seeking judicial declaration that Parcel 4, Psu-2031 is within its territorial jurisdiction and accounting for proceeds collected by respondents.
City of Makati and City of Taguig opposed the complaint and moved to dismiss on grounds including lack of jurisdiction, noncompliance with the Local Government Code procedures, prescription, and forum shopping.
The RTC, in a May 10, 2013 Resolution, granted Makati's motion and dismissed the complaint for lack of jurisdiction due to noncompliance with Section 118 and Section 119 of the Local Government Code of 1991 and Articles 16 and 17 of Rule III of the Implementing Rules and Regulations.
The Court of Appeals affirmed the RTC in its January 29, 2015 Decision and denied Pateros' motion for reconsideration in its September 24, 2015 Resolution.
The petition for review under Rule 45 sought reversal of the CA rulings and reinstatement of Civil Case No. 73387-TG, and this Court granted the petition and ordered reinstatement.

Key Factual Allegations

Pateros alleged continuous exercise of jurisdiction over the areas comprising Parcel 4 since its establishment as an independent town in 1801 and cited historical maps and acts to support its claim.
Pateros asserted that parcels included in Fort McKinley/Fort Bonifacio were taken away from its original territory following cadastral actions and presidential proclamations.
Pateros presented multiple sanggunian resolutions documenting its attempts to initiate council-to-council dialogues with Makati and Taguig pursuant to the LGC and its IRR.
Makati relied on historical surveys, demographic data, and cadastral approvals to assert its jurisdictional claim over significant portions of the disputed area.
Taguig relied on its own cadastral mapping, historical acts, and the decision in Civil Case No. 63896 to assert territorial title over Parcels 3 and 4.

Statutory Framework

Section 118, Section 119, and Rule III of the Implementing Rules and Regulations of the Local Government Code of 1991 prescribe a multi-step, sanggunian-based procedure for amicable settlement and subsequent adjudication of boundary disputes.
Article 17 of Rule III sets forth the petition-by-resolution mechanism, answer period, hearing schedule, joint hearings, certification upon failure to settle, decision timetable, and the right to appeal the sanggunian decision to the Regional Trial Court.
The procedural directives in G.R. No. 157714 instructed Pateros and Makati to comply with Section 118(d) and (e) and Rule III without prejudice to judicial recourse.

Procedural History and Prior Decisions

Pateros previously pursued Civil Case No. 93-4529 and this Court in G.R. No. 157714 denied relief but directed compliance with the LGC procedures while relaxing rules to address the dispute.
Taguig's Civil Case No. 63896 resulted in an RTC Pasig Decision favorable to Taguig, which was later the subject of appellate and Supreme Court proceedings culminating in G.R. No. 235316 where this Court ruled that Taguig presented more convincing evidence over Makati.
The CA in CA-G.R. CV No. 101512 dismissed Pateros' case on the ground that original jurisdiction to try such disputes belonged exclusively to the joint sanggunians and that the RTC could only exercise appellate jurisdiction under Section 119.

Issues Presented

Whether Pateros complied with the requirements of Section 118(d) and (e) of the LGC and Rule III of the IRR as