In Barangay Sangalang v. Barangay Maguihan, the Supreme Court addressed a dispute over territorial jurisdiction between two barangays. The Court ruled that in boundary disputes, cadastral maps approved by the Director of Lands hold more weight than tax declarations issued by the local assessor’s office. This decision provides clarity on the type of evidence that is given more weight in resolving boundary disputes between local government units, emphasizing the importance of technical land surveys conducted by the responsible government agency. The ruling has practical implications for local governance, property rights, and revenue collection in disputed areas.

Dividing Lines: When Barangay Borders Spark Legal Battles in Lemery, Batangas

The case originated from a territorial dispute between Barangay Sangalang and Barangay Maguihan, both located in Lemery, Batangas. At the heart of the matter were properties covered by Tax Declaration Nos. 038-00315, 038-00316, and 038-00317. Barangay Sangalang claimed that these properties fell within their jurisdiction, while Barangay Maguihan asserted they were within their territorial boundaries. Initially, the Sangguniang Bayan of Lemery sided with Barangay Sangalang, but Barangay Maguihan appealed this decision to the Regional Trial Court (RTC).

The RTC reversed the Sangguniang Bayan’s decision, favoring Barangay Maguihan. This led Barangay Sangalang to appeal to the Court of Appeals (CA), which dismissed the appeal on procedural grounds, stating that the wrong mode of appeal was used. The CA also noted deficiencies in the appellant’s brief. Undeterred, Barangay Sangalang elevated the case to the Supreme Court, arguing that the CA had erred in prioritizing technicalities over substantial justice and that the RTC had overstepped its authority in reversing the Sangguniang Bayan’s decision.

At the heart of the procedural issues was the mode of appeal taken by Barangay Sangalang. The Supreme Court agreed with the CA that Barangay Sangalang had used the wrong remedy. Section 2, Rule 41 of the Rules of Court clearly distinguishes between ordinary appeals and petitions for review. It states:

Sec. 2. Modes of appeal.

(b) Petition for review. – The appeal to the Court of Appeals in cases decided by the Regional Trial Court in the exercise of its appellate jurisdiction shall be by petition for review in accordance with Rule 42.

Since the RTC was exercising its appellate jurisdiction when it reviewed the Sangguniang Bayan’s decision, the proper mode of appeal to the CA was a petition for review under Rule 42, not an ordinary appeal under Rule 41. However, the Supreme Court also acknowledged the need for a liberal construction of the Rules of Court, particularly when substantial justice is at stake. The Court cited Ong Lim Sing, Jr. v. FEB Leasing and Finance Corporation, emphasizing that technicalities should not override the pursuit of justice.

Courts have the prerogative to relax procedural rules of even the most mandatory character, mindful of the duty to reconcile both the need to speedily put an end to litigation and the parties’ right to due process. In numerous cases, this Court has allowed liberal construction of the rules when to do so would serve the demands of substantial justice and equity.

Despite the procedural misstep, the Supreme Court chose to address the substantive merits of the case due to its protracted nature and the importance of resolving the boundary dispute between the barangays. This decision underscores the Court’s commitment to resolving disputes on their merits rather than dismissing them on technicalities, especially when public interest is involved.

Turning to the substantive issue of which barangay the disputed lots belonged to, the Supreme Court examined the evidence presented by both parties. Barangay Sangalang relied on certifications from the Provincial Assessor’s Office, tax declarations, and an old map of the barangay. On the other hand, Barangay Maguihan presented a certified copy of the cadastral map of the Lemery Cadastre, approved by the Director of Lands, and a certification from the Community Environment and Natural Resources Office (CENRO).

The Supreme Court emphasized that cadastral maps approved by the Director of Lands are more authoritative than tax declarations from the assessor’s office. The Court referred to Article 17, Rule III of the Rules and Regulations Implementing the Local Government Code of 1991, which outlines the documents required for settling boundary disputes. While neither party had fully complied with these requirements, the Court found Barangay Maguihan’s evidence more persuasive.

The Court highlighted the expertise of the Land Management Bureau (LMB) in land surveys, stating that this agency is the government body responsible for these matters. The Court agreed with the RTC’s observation that the primary duty of provincial and municipal assessors is tax assessment, not land surveying. Therefore, in the absence of evidence proving the cadastral map inaccurate or invalid, it should be given greater weight.

Moreover, the Supreme Court affirmed the RTC’s view that the population of a barangay does not determine its territorial jurisdiction. The Court stressed that territorial boundaries are defined by official maps and legal documents, not by the preferences of residents. This approach prevents endless litigation and ensures stability in local governance.

FAQs

What was the central issue in the Barangay Sangalang v. Barangay Maguihan case?	The case revolved around a territorial dispute between two barangays, Barangay Sangalang and Barangay Maguihan, concerning the jurisdiction over specific properties covered by certain tax declarations.
What evidence did Barangay Sangalang present to support its claim?	Barangay Sangalang presented certifications from the Provincial Assessor’s Office, copies of tax declarations for the properties in question, and an old map of Barangay Sangalang.
What evidence did Barangay Maguihan present to support its claim?	Barangay Maguihan presented a certified copy of the cadastral map of the Lemery Cadastre, approved by the Director of Lands, and a certification from the Community Environment and Natural Resources Office (CENRO).
What is a cadastral map, and why was it important in this case?	A cadastral map is an official map showing the boundaries and ownership of land parcels within a specific area. It was important because the Supreme Court considered it a more reliable source of information about territorial jurisdiction than tax declarations.
Which government agency is primarily responsible for land surveys?	The Land Management Bureau (LMB) is the principal government agency tasked with the survey of lands. The Court considered the LMB’s expertise in land surveys when evaluating the evidence presented by the parties.
What was the Court of Appeals’ initial ruling in the case?	The Court of Appeals dismissed the appeal filed by Barangay Sangalang on procedural grounds, stating that it availed itself of the wrong remedy and also noting deficiencies in the appellant’s brief.
What was the Supreme Court’s stance on the procedural issues raised in the case?	The Supreme Court acknowledged that Barangay Sangalang had used the wrong mode of appeal but chose to address the substantive merits of the case in the interest of justice and to resolve the protracted dispute.
What was the ultimate decision of the Supreme Court in this case?	The Supreme Court reversed the Court of Appeals’ decision and affirmed the Regional Trial Court’s ruling, declaring that the disputed properties were within the territorial jurisdiction of Barangay Maguihan, based on the cadastral map.

The Supreme Court’s decision in Barangay Sangalang v. Barangay Maguihan provides important guidance on resolving territorial disputes between barangays. It clarifies that cadastral maps approved by the Director of Lands are more authoritative than tax declarations in determining territorial jurisdiction. This ruling underscores the importance of relying on technical expertise and official records in resolving boundary disputes, ensuring clarity and stability in local governance.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Barangay Sangalang, REPRESENTED BY ITS CHAIRMAN DANTE C. MARCELLANA, Petitioner, vs. Barangay Maguihan, REPRESENTED BY ITS CHAIRMAN ARNULFO VILLAREZ, Respondent., G.R. No. 159792, December 23, 2009