Case Summary (G.R. No. 209146)
Relevant Proceedings
The conflict began with Civil Case No. C-566 filed by the respondents against the petitioners for "Recovery and Declaration of Political Jurisdiction/Dominion and Mandamus." The petitioners challenged two orders from Judge Calabocal—one issued on April 23, 2013, which denied their defense of lack of jurisdiction, and another on July 17, 2013, which denied their motion for reconsideration.
Background of the Dispute
The issue traces back to an informal agreement made between the mayors of Bulalacao and Caluya in the late 1970s, wherein the administration of Liwagao Island was lent to Caluya. Although the island was allegedly returned to Bulalacao by 1987, Caluya continued to exercise administrative authority. This was exemplified by the Sangguniang Panlalawigan of Oriental Mindoro's resolution in 2002 confirming its jurisdiction over the island, while the Municipality of Caluya continued its claims and collection of taxes.
Procedural History in the RTC
The RTC ruled against the petitioners, stating the case involved claims of ownership rather than merely a boundary dispute, thereby denying the jurisdictional defense raised by petitioners. Upon motion for reconsideration, the RTC reaffirmed its stance, asserting that Bulalacao had established territorial claims over the island based on historical documents.
Petition in the Supreme Court
Subsequently, the petitioners sought a writ of certiorari and prohibition from the Supreme Court, contending that the RTC's jurisdiction was improperly assumed given that boundary disputes should be settled by the Sangguniang Panlalawigans as per the Local Government Code. They requested to enjoin the RTC from further proceedings and dismiss the case altogether.
Arguments by Petitioners
The petitioners articulated multiple arguments:
- They insisted that the RTC had committed grave abuse of discretion by ruling that the matter did not involve a boundary dispute.
- They asserted that the Sangguniang Panlalawigans of both provinces have primary jurisdiction over any boundary disputes, per the Local Government Code.
- They contended that the RTC should only be hearing appeals from resolutions made by the sanggunian and since there was no such petition or resolution, the RTC lacked jurisdiction.
- They further claimed the petition filed by the respondents was not a proper petition as it did not conform to the requisite procedural mechanisms stipulated in the Local Government Code's Implementing Rules and Regulations (IRR).
Arguments by Respondents
On their part, the respondents raised procedural and jurisdictional objections against the petitioners:
- They argued that the petition was filed out of time and did not comply with necessary procedural requirements.
- They claimed that the case before the RTC did not pertain to a boundary dispute but was an original action for the recovery of jurisdiction and dominion over Liwagao Island.
- They emphasized that the ownership boundary had long been established and the definition of boundary disputes did not apply to their claim.
- They maintained that the Sangguniang Panlalawigan of Antique's refusal to amicably settle the dispute cleared the way for the RTC to take cognizance of the case.
Court's Ruling
The Supreme Court dismissed the petition, affirming that the RTC
...continue readingCase Syllabus (G.R. No. 209146)
Case Overview
- The case involves a Petition for Certiorari and Prohibition filed by the Province of Antique and the Municipality of Caluya against Judge Recto A. Calabocal, the Regional Trial Court of Roxas, Oriental Mindoro, along with the Province of Oriental Mindoro and the Municipality of Bulalacao.
- The dispute centers on territorial jurisdiction and control over Liwagao Island, a 114-hectare island located between the Province of Antique and the Province of Oriental Mindoro.
- The case originated from Civil Case No. C-566, where respondents sought a "Recovery and Declaration of Political Jurisdiction/Dominion and Mandamus."
Factual Background
- In 1978-1979, an oral agreement was made between then-Mayors Dolores Bago of Bulalacao and Oscar Lim of Caluya regarding the administration of Liwagao Island, which was to be returned upon termination of their terms.
- Following the end of their terms in 1987, while Mayor Lim allegedly returned the island, the Municipality of Caluya continued to administer it.
- In 2002, the Sangguniang Panlalawigan of Oriental Mindoro passed a resolution asserting jurisdiction over Liwagao Island, but the Municipality of Caluya and the Province of Antique continued to collect taxes from its inhabitants.
- In 2012, attempts to resolve the jurisdictional claims through a joint session were rejected by the Sangguniang Panlalawigan of Antique.
- The respondents filed a petition in September 2012, asserting their jurisdiction over Liwagao Island.
Orders of the Regional Trial Court
- On April 23, 2013, the RTC denied the petitioners' affirmative defense of lack of jurisdiction, stating the case was not merely a boundary dispute but involved claims of ownership.