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.
A

Case Summary (G.R. No. 220824)

Core factual background

The controversy concerns competing territorial claims over portions of the former Fort William McKinley / Fort Bonifacio (including Barangays Cembo, South Cembo, West Rembo, East Rembo, Comembo, Pembo, Pitogo and Bonifacio Global City) claimed by Makati, Taguig and Pateros. Presidential Proclamations Nos. 2475 (1986) and 518 (1991) declared those areas part of Makati. Pateros traced an historic claim to Parcel 4, Psu‑2031 (about 766.0028 ha.), alleging historical jurisdiction and payment of certain taxes by residents to Pateros; Taguig likewise asserted claim over Parcels 3 and 4; Makati similarly asserted jurisdiction and asserted that cadastral and official acts placed the disputed areas within Makati.

Procedural history leading to the present petition

Relevant prior proceedings include: (a) Pateros’ Civil Case No. 93‑4529 (1993) challenging Proc. No. 2475, which was dismissed for lack of jurisdiction and whose appellate path to the Supreme Court led to G.R. No. 157714 (2009) where the High Court denied the petition but directed the parties to comply with Section 118(d)–(e) of the LGC and Rule III (IRR) “without prejudice to judicial recourse”; (b) Taguig’s Civil Case No. 63896 (RTC Pasig, Branch 153) and subsequent appeals which culminated in litigation between Taguig and Makati resolved in a later Supreme Court decision (G.R. No. 235316) that addressed the Taguig–Makati dispute on the merits; and (c) Pateros’ filing of Civil Case No. 73387‑TG in RTC Pasig (2012) seeking declaration that Parcel 4 of Psu‑2031 is within Pateros’ jurisdiction and relief against Makati and Taguig.

RTC Pasig’s disposition and rationale

RTC Pasig, Branch 271 granted Makati’s motion to dismiss (May 10, 2013), holding that Pateros failed to comply with Sections 118 and 119 of the LGC and Articles 16 and 17 of the IRR (Rule III). The RTC found that the required joint referral and joint hearing by the respective sanggunians had not occurred, that Pateros’ unilateral certification and “formal trial” by its own sanggunian did not satisfy the IRR requirements, and therefore the court lacked jurisdiction; issues such as correct filing fees and forum‑shopping were deemed unnecessary to decide given the jurisdictional dismissal.

Court of Appeals’ ruling and reasoning

The Court of Appeals dismissed Pateros’ appeal, affirming that under Sec. 118(d) original jurisdiction to settle boundary disputes between a component city/municipality and a highly urbanized city, or between highly urbanized cities, is vested in the “sanggunians concerned” which must act jointly. Because no decision was rendered jointly by the sanggunians of Pateros, Makati and Taguig, the CA concluded RTC Pasig had neither original nor appellate jurisdiction and dismissal was warranted.

Issues presented to the Supreme Court

The Supreme Court identified and resolved three principal issues: (1) whether Pateros complied with Secs. 118(d) and (e) of the LGC and Rule III of the IRR as directed in G.R. No. 157714; (2) whether Taguig’s non‑response justified Pateros’ filing of 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.

Pateros’ arguments on compliance and denial of forum‑shopping

Pateros argued it expended all reasonable efforts to initiate the LGC/IRR process (resolutions, joint resolution with Makati, repeated invitations to Taguig) and that Taguig’s and Makati’s refusal or inaction made joint compliance impossible. Pateros contended that Sec. 118 requires referral “to the respective sanggunians” and promotes amicable settlement “as much as possible,” so the law does not mandate a joint resolution when other LGUs refuse to participate; accordingly Pateros asserted its right to judicial recourse “without prejudice” after substantial compliance. Pateros denied forum‑shopping, explained documentary attachments and authority of its mayor to file, and relied on the prior Supreme Court direction in G.R. No. 157714 as mandating the LGC procedure but preserving judicial remedies.

Respondents’ contentions (Taguig and Makati)

Taguig and Makati urged dismissal and denial of relief on multiple grounds: failure to comply with Sec. 118/IRR (absence of a joint referral and joint hearing by sanggunians), procedural defects (non‑payment of docket and statutory fees, missing attachments, improper certification of non‑forum‑shopping, lack of authority for signatory), and forum‑shopping. Taguig emphasized that the statutory scheme contemplates the “sanggunian concerned” acting jointly and that unilateral Pateros resolutions cannot substitute. Makati further relied on the CA’s prior decision in CA‑G.R. CV No. 98377 (and the Supreme Court’s subsequent proceedings between Makati and Taguig culminating in G.R. No. 235316) to assert that the disputed areas were within Makati and that RTC original jurisdiction was inappropriate.

Supreme Court’s interpretive framework and reliance on precedent

The Court reiterated the statutory scheme in Secs. 118–119 LGC and Rule III of the IRR governing amicable settlement and sanggunian jurisdiction. The Court emphasized that where the LGC assigns initial jurisdiction to the “sanggunians concerned” acting jointly, the sanggunian body of each contending LGU must be given a fair opportunity to participate. The Court explained, however, that these statutory procedures presuppose cooperation by all contending LGUs and that prior jurisprudence (Province of Antique v. Judge Calabocal) supports judicial relief where the opposing sanggunian’s categorical refusal or inaction makes compliance futile and would otherwise leave the initiating LGU without remedy.

Application to the facts: Pateros’ substantial compliance and the effect of Taguig’s inaction

Applying the LGC and the cited precedent, the Supreme Court found that Pateros did initiate the LGC/IRR process: Pateros’ Sangguniang Bayan passed resolutions requesting joint dialogue; Makati initially participated in a joint resolution and dialogued twice; Taguig failed to respond to invitations. The Court held that Taguig’s silence and refusal manifested unwillingness to engage in the statutorily prescribed settlement process and that such inaction effectively rendered joint compliance impossible. Given those circumstances, the Court concluded Pateros’ unilateral certification and resort to judicial recourse were warranted and consistent with the remedial intent of the LGC and the Supreme Court’s prior instruction in G.R. No. 157714 (which preserved judicial recourse “without prejudice”).

Jurisdictional conclusion and treatment of the action

The Supreme Court held that RTC Pasig, Branch 271 had jurisdiction to entertain Pateros’ original action under the circumstances because the sanggunians’ failure (especially Taguig’s) to cooperate made exclusive initial resolution by the joint sanggunian impracticable. The petition was properly treated as an original action (not an appeal under Sec. 119) and Pateros was not left without a legal remedy to assert its territorial claims.

Res judicata and effect

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