In a dispute between the Municipality of Bakun, Benguet, and the Municipality of Sugpon, Ilocos Sur, the Supreme Court affirmed the latter’s territorial jurisdiction over a contested 1,117.20-hectare parcel of land. The Court emphasized that in boundary disputes, preponderance of evidence determines the outcome, and Sugpon successfully demonstrated its claim through credible maps, certifications, and historical occupation. This ruling underscores the importance of presenting compelling evidence to support territorial claims and clarifies the application of old legislations in modern boundary disputes.
When Old Laws Collide with Modern Maps: Who Decides a Boundary?
The heart of the matter lies in a territorial dispute between the Municipality of Bakun, Benguet, and the Municipality of Sugpon, Ilocos Sur, concerning a 1,117.20-hectare parcel of land. Bakun anchored its claim on Act Nos. 1646 and 2877, arguing that these laws defined the boundary between the two municipalities. Sugpon, however, presented maps, certifications, and other documents to prove that the disputed area fell within its territorial jurisdiction. The Regional Trial Court (RTC) and the Court of Appeals (CA) sided with Sugpon, leading Bakun to elevate the case to the Supreme Court. The central legal question revolves around which evidence carries more weight in determining municipal boundaries, especially when historical laws are juxtaposed against modern cartographic and administrative data.
The Supreme Court, in its analysis, reiterated the principle that it is not a trier of facts and generally confines itself to questions of law in petitions for review on certiorari. This means the Court typically does not re-evaluate the factual findings of lower courts unless specific exceptions apply. Here, Bakun failed to demonstrate any compelling reason for the Court to deviate from this rule. The CA and RTC findings, which favored Sugpon’s claim, were deemed adequately supported by the evidence presented.
Sugpon’s case rested on a collection of documentary evidence that painted a consistent picture of the disputed area belonging to its territory. The Administrative Map of Benguet showed the land outside of Benguet’s boundaries and within Sugpon. Reinforcing this were Land Classification Maps, the Topographic and Administrative Map of Ilocos Sur, and certifications from the Department of Environment and Natural Resources (DENR) and the Department of Agrarian Reform (DAR), all indicating the location of the land within Sugpon’s jurisdiction. These documents are considered reliable due to the presumption of regularity in their creation and issuance by public officers. As the CA aptly stated:
These documents are reliable to establish the extent of territory of these municipalities. In the absence of evidence of falsity of these documents, We treat them as credible proof of the land boundaries for they are public documents which were made pursuant to law and issued by public officers whose performance of duty enjoys the presumption of regularity. These maps are indispensable to determine the range and extent of the territory where the government can exercise powers and its technical description to clearly delineate one territory from the other.
Further bolstering Sugpon’s claim was evidence demonstrating its administrative control and connection to the disputed area. A certification from the Schools Division Superintendent confirmed that Nagawa Elementary School, located in the contested area, fell under the jurisdiction of the Department of Education, Division of Ilocos Sur. Evidence also showed that Sugpon had established voting centers in the barangays within the disputed area, and residents were registered voters of Sugpon. This demonstrated a clear exercise of governmental functions and provision of services by Sugpon within the territory in question.
The Certificate of Ancestral Domain Title presented by Sugpon further solidified its claim by demonstrating continuous occupation, possession, and utilization of the area by indigenous people and residents of Sugpon. While the determination of jurisdiction cannot be solely based on the populace’s preference, the petitions from residents, combined with other documentary evidence, collectively indicated that the disputed areas were historically and presently part of Sugpon. These petitions, though not determinative on their own, added weight to the overall evidence supporting Sugpon’s claim. The court considered the historical connection and long-standing presence of Sugpon’s residents in the area.
Contrastingly, Bakun’s reliance on Act Nos. 1646 and 2877 proved insufficient. These laws, enacted in the early 20th century, aimed to establish boundary lines between the sub-province of Amburayan and the provinces of Ilocos Sur and La Union. However, the Supreme Court concurred with the lower courts that these laws did not provide a clear and specific delineation of the boundaries between Bakun and Sugpon. The laws were deemed too vague to resolve the contemporary boundary dispute. The RTC emphasized this point:
[Act] Nos. 1646 and 2877, dated May 15, 1907 and February 4, 1920, respectively which established the boundary of the subprovince of Amburayan and Ilocos Sur and abolished said subprovince of Amburayan would not provide a clear solution to this controversy regarding the exact boundaries of these two municipalities as they are vague on the matter and would not specifically delineate the metes and bounds of Bakun, Benguet and Sugpon, Ilocos Sur.
Even applying the guidelines set forth in these older acts, Bakun failed to demonstrate that the disputed properties fell within its territory. The evidence presented by Bakun, such as payrolls, disbursement vouchers, and tax declarations, merely indicated acts of dominion over the property but did not conclusively prove that the modified boundary line encompassed the disputed areas. These actions, while demonstrating Bakun’s involvement in the area, did not outweigh the comprehensive evidence presented by Sugpon establishing its historical and administrative connection to the land.
Ultimately, the Supreme Court’s decision hinged on the principle of preponderance of evidence. Sugpon presented a more compelling case by providing a variety of documents, including maps, certifications, and historical records, that consistently demonstrated its territorial claim. Bakun’s reliance on older, less specific laws and its failure to rebut Sugpon’s evidence led to the denial of its petition. This case highlights the importance of maintaining accurate records and presenting clear, persuasive evidence in boundary disputes.
FAQs
| What was the key issue in this case? | The central issue was determining the correct territorial boundary between the Municipality of Bakun, Benguet, and the Municipality of Sugpon, Ilocos Sur, regarding a disputed 1,117.20-hectare area. The Supreme Court had to decide which municipality had the rightful claim based on the evidence presented. |
| What evidence did Sugpon present to support its claim? | Sugpon presented various maps, certifications from government agencies like DENR and DAR, tax declarations, a Certificate of Ancestral Domain Title, and petitions from residents, all indicating that the disputed area fell within its territorial jurisdiction. They also showed they provided government services within the area. |
| Why were Act Nos. 1646 and 2877 insufficient for Bakun’s claim? | The Supreme Court found that these laws, which aimed to establish boundary lines in the early 20th century, were too vague and did not specifically delineate the boundaries between Bakun and Sugpon. The laws did not provide enough detail to resolve the modern boundary dispute. |
| What does “preponderance of evidence” mean in this context? | “Preponderance of evidence” means that the evidence presented by one party is more convincing than the evidence offered by the opposing party. In this case, Sugpon’s evidence was deemed more credible and persuasive than Bakun’s. |
| Can residents’ petitions determine jurisdiction in boundary disputes? | While residents’ petitions alone cannot determine jurisdiction, they can add weight to the overall evidence, especially when combined with other documentary evidence and historical records demonstrating a municipality’s presence and control over the area. The sentiment of the residents is important to the court. |
| What is the significance of the presumption of regularity in this case? | The presumption of regularity applies to public documents issued by government officials in the performance of their duties. The court treated Sugpon’s maps and certifications as credible evidence of land boundaries because they were presumed to have been created accurately and legally. |
| Why didn’t the Supreme Court re-evaluate the facts of the case? | The Supreme Court is generally not a trier of facts and typically confines itself to questions of law. Unless specific exceptions apply, the Court will not re-evaluate the factual findings of lower courts, which in this case were deemed adequately supported by the evidence. |
| What was the key takeaway from this case? | The key takeaway is the importance of presenting compelling and credible evidence to support territorial claims in boundary disputes. This evidence should include maps, certifications, historical records, and evidence of administrative control. |
This case serves as a crucial reminder for local government units to maintain meticulous records and proactively safeguard their territorial boundaries. The ruling underscores that in boundary disputes, a well-documented and consistently supported claim, backed by credible evidence, will likely prevail. Moving forward, municipalities should regularly review and update their boundary documentation to prevent future disputes.
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: MUNICIPALITY OF BAKUN VS. MUNICIPALITY OF SUGPON, G.R. No. 241370, April 20, 2022