Navigating Local Boundary Disputes: The Importance of Proper Procedure

G.R. No. 269159, November 04, 2024, THE CITY OF CALOOCAN VS. THE CITY OF MALABON

Imagine two neighboring cities disagreeing over which one has jurisdiction over a particular area. Residents are unsure where to pay taxes, and local officials are at odds. This real-world scenario highlights the complexities of boundary disputes between local government units (LGUs). This case between Caloocan and Malabon underscores the critical importance of adhering to the procedures outlined in the Local Government Code (LGC) when resolving such disputes. It emphasizes that prematurely resorting to the courts, without first exhausting administrative remedies, can lead to the dismissal of the case.

The Local Government Code and Boundary Disputes

The Philippine legal system recognizes that disagreements between LGUs can arise regarding their territorial boundaries. To address these issues efficiently and amicably, the Local Government Code of 1991 (RA 7160) provides a specific framework for resolving boundary disputes. This framework prioritizes settlement through the respective Sanggunians (local legislative bodies) of the LGUs involved.

Section 118 of the LGC clearly outlines the jurisdictional responsibility for settling boundary disputes. It mandates that disputes between two or more highly urbanized cities, like Caloocan and Malabon, be jointly referred for settlement to their respective Sanggunians. The exact text of Section 118 states:

“Section. 118. Jurisdictional Responsibility for Settlement of Boundary Disputes. — Boundary disputes between and among local government units shall, as much as possible, be settled amicably. To this end:
(d) Boundary disputes involving a component city or municipality on the one hand and a highly urbanized city on the other, or two (2) or more highly urbanized cities, shall be jointly referred for settlement to the respective sanggunians of the parties.”

This provision underscores the importance of exhausting all administrative avenues before seeking judicial intervention. The LGC’s preference for amicable settlement reflects a policy aimed at fostering cooperation and minimizing legal battles between LGUs.

Caloocan vs. Malabon: A Tale of Two Cities

The dispute began when Caloocan, represented by its mayor, questioned the constitutionality of Republic Act No. (RA) 9019, the Charter of the City of Malabon. Caloocan argued that Section 2 of RA 9019, which defines the boundaries of Malabon, encroached upon its territory without a proper plebiscite as required by the Constitution.

Here’s a breakdown of the case’s journey:

• Initial Petition: A group of Caloocan residents and officials filed a petition for declaratory relief, challenging the constitutionality of RA 9019.
• RTC Decision: The Regional Trial Court (RTC) initially sided with Caloocan, declaring RA 9019 unconstitutional.
• CA Reversal: The Court of Appeals (CA) reversed the RTC’s decision, emphasizing that the dispute should have first been referred to the Sanggunians of both cities for amicable settlement.

The CA emphasized the necessity of following the procedure laid out in Section 118 of the LGC. The Court quoted, “recourse to the available administrative remedy should have been availed of first before immediately resorting to judicial intervention.”
The Supreme Court agreed with the Court of Appeals, the SC emphasized that the petition for declaratory relief was not the proper remedy. The Court reasoned:

“Under the LGC, boundary disputes between and among LGUs must first be referred jointly for amicable settlement to the Sanggunians of the concerned LGUs pursuant to Section 118 of the LGC, and it is only upon failure of these intermediary steps will resort to the RTC follow, as specifically provided in Section 119 of the LGC.“

The Supreme Court reiterated the importance of settling such disputes through the mechanisms provided by the LGC before seeking judicial intervention.

Practical Implications for LGUs and Residents

This case serves as a reminder to LGUs and their constituents about the proper channels for resolving boundary disputes. It highlights the importance of following the administrative procedures outlined in the LGC before resorting to costly and time-consuming litigation.

Imagine a scenario where a business owner is unsure whether to pay local taxes to Caloocan or Malabon. This uncertainty can create significant legal and financial challenges for the business. By adhering to the LGC’s dispute resolution mechanisms, the cities can provide clarity and stability for their residents and businesses.

Key Lessons:

• Exhaust Administrative Remedies: Always attempt to resolve boundary disputes through the Sanggunians before seeking court intervention.
• Understand the LGC: Familiarize yourself with the provisions of the Local Government Code regarding boundary disputes.
• Seek Legal Advice: Consult with a qualified lawyer to ensure compliance with all legal requirements.

Frequently Asked Questions

Q: What is a boundary dispute between LGUs?

A: A boundary dispute occurs when two or more LGUs claim jurisdiction over the same territory.

Q: What is the first step in resolving a boundary dispute?

A: The first step is to jointly refer the dispute to the Sanggunians of the LGUs involved for amicable settlement.

Q: What happens if the Sanggunians cannot reach an agreement?

A: If the Sanggunians fail to reach an agreement within 60 days, they must issue a certification to that effect. The dispute can then be elevated to the Regional Trial Court (RTC).

Q: Can a court immediately resolve a boundary dispute?

A: Generally, no. The LGC requires that administrative remedies be exhausted first before resorting to judicial intervention.

Q: What is the role of the RTC in a boundary dispute?

A: The RTC hears appeals from the decisions of the Sanggunians and must decide the appeal within one year.

Q: What is a petition for declaratory relief?

A: A petition for declaratory relief is a legal action seeking a court’s interpretation of a statute or contract. However, it’s not appropriate if there’s already a breach or violation, or if another remedy is more suitable.

Q: What happens if the Local Government Code procedures are not followed?

A: Failure to comply with the LGC’s procedures can result in the dismissal of the case, as seen in this Caloocan vs. Malabon dispute.

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