Case Summary (G.R. No. 140474)
Case Background
On October 16, 1980, the Municipality of Sta. Fe initiated Civil Case No. 2821 in the RTC of Bayombong, Nueva Vizcaya, seeking to resolve a boundary dispute involving the aforementioned barangays. After proceeding through various stages, including a pre-trial that did not result in an amicable settlement, the trial nearly concluded until the court recognized a jurisdictional issue in December 1988. The court suspended proceedings and referred the matter to the Sangguniang Panlalawigan of Nueva Vizcaya for potential resolution.
Sangguniang Panlalawigan Involvement
The Sangguniang Panlalawigan subsequently reviewed previous resolutions and supported a recommendation pertaining to the boundary dispute, notably Resolution No. 64 from September 14, 1979, favoring Aritao. This led to Resolution No. 357 on November 13, 1989, which endorsed the referral back to the RTC while maintaining the status quo.
Court Proceedings and Dismissal
Respondent Aritao then filed for dismissal in June 1992, arguing that jurisdiction over boundary disputes had shifted from the RTC to the Sangguniang Panlalawigan following established legislative changes. On August 27, 1992, the RTC consequently ruled to dismiss the case, referencing the Supreme Court's earlier decision in Municipality of Sogod v. Rosal, which established jurisdictional precedence.
Court of Appeals Decision
Upon appeal, the Court of Appeals affirmed the RTC's dismissal, reiterating that the 1987 Constitution and the Local Government Code of 1991 have set new jurisdictional boundaries for resolving municipal conflict. This included mechanisms for public participation via plebiscites in boundary alterations, reinforcing the appropriate legislative framework.
Legal Framework Analysis
The analysis highlights that the jurisdiction for municipal boundary disputes transitioned from the RTCs to the Sangguniang Panlalawigan as reflected in both the 1987 Constitution and the Local Government Code of 1991. The latter codifies the procedural responsibilities and authority of the Sangguniang Panlalawigan to resolve such disputes, which now requires formal hearings and decisions, contrasting earlier processes where the RTC sat as the first-instance tribunal.
Affirmation of Dismissal
The appellate court underscored that subsequent legislation regarding boundary disputes must receive retroactive application in relation to pending cases. This means the RTC acted within its bounds when it acknowledged its loss of juris
...continue readingCase Syllabus (G.R. No. 140474)
Overview of the Case
- The case involves an appeal by the Municipality of Sta. Fe against the Municipality of Aritao regarding a boundary dispute.
- This appeal was filed under Rule 45 of the Rules of Court, contesting the Court of Appeals' decision dated September 30, 1999.
- The Court of Appeals affirmed the Regional Trial Court's (RTC) order dismissing Civil Case No. 2821 for lack of jurisdiction.
Background of the Case
- On October 16, 1980, the Municipality of Sta. Fe filed a civil case regarding a boundary dispute between the barangays of Bantinan and Canabuan in the RTC of Bayombong, Nueva Vizcaya.
- During the pre-trial stage, the parties were unable to reach an amicable settlement, leading to a trial on the merits.
- Just before the trial concluded, the court recognized an oversight concerning its jurisdiction and ordered a suspension of proceedings on December 9, 1988, referring the case to the Sangguniang Panlalawigan of Nueva Vizcaya.
Referral to Sangguniang Panlalawigan
- The Sangguniang Panlalawigan referred the matter to its Committee on Legal Affairs, which recommended the adoption of Resolution No. 64.
- This resolution adjudicated that the barangays in question belonged to the territorial jurisdiction of the Municipality of Aritao and enjoined Sta. Fe from exercising governmental functions in that area.
- On November 13, 1989, the Sangguniang Panlalawigan approved the recommendation but referred the dispute back to the RTC for further proceedings.
RTC's Orders and Motions
- Respondent Municipality of Aritao later moved to consider Resolution No. 64 as final and executory. However, the RTC denied this