Procedural Flexibility is Key in Resolving Boundary Disputes

Municipality of Bakun, Benguet v. Municipality of Sugpon, Ilocos Sur, G.R. No. 224335, March 02, 2020

Imagine two neighboring towns locked in a decades-long dispute over a piece of land, each claiming it as their own. This scenario isn’t just a plot for a drama series; it’s a real issue that can affect communities and their development. The case of the Municipality of Bakun, Benguet versus the Municipality of Sugpon, Ilocos Sur, decided by the Philippine Supreme Court, sheds light on how such disputes are resolved and the importance of procedural flexibility in achieving justice.

The heart of this case revolves around a 1,118-hectare parcel of land claimed by both municipalities. The central legal question was whether the appeal process followed by Sugpon complied with the procedural requirements of the Rules of Court, specifically Rule 40, in the context of a boundary dispute under the Local Government Code (LGC).

Legal Context

Boundary disputes in the Philippines are governed by the Local Government Code of 1991 and its Implementing Rules and Regulations (IRR). According to Article 17 of the IRR, any party can appeal the decision of the sanggunian concerned to the Regional Trial Court (RTC) within the time and manner prescribed by the Rules of Court. This provision emphasizes the role of the RTC in resolving such disputes and underscores the need for a clear appeal process.

The term sanggunian refers to the local legislative body, such as the Sangguniang Panlalawigan at the provincial level or the Sangguniang Bayan at the municipal level. In the context of boundary disputes, an Ad Hoc Joint Sanggunian may be formed to resolve the issue, as was the case between Bakun and Sugpon.

Rule 40 of the Revised Rules of Court outlines the procedure for appeals from the Municipal Trial Courts to the RTC. However, its applicability to boundary disputes, which originate from a sanggunian’s decision, has been a point of contention. The Supreme Court has previously ruled that procedural rules should not be applied strictly if doing so would frustrate justice, as seen in cases like Municipality of Pateros v. Court of Appeals.

Case Breakdown

The dispute began when both municipalities claimed ownership of a 1,118-hectare land. An Ad Hoc Joint Sanggunian was formed, and after failed attempts at settlement, it issued Joint Resolution No. 1, Series of 2014, favoring Bakun. Dissatisfied, Sugpon appealed to the RTC.

Sugpon’s appeal process raised several procedural questions. They served a Notice of Appeal to the Sangguniang Panlalawigan of Benguet, not the Joint Sanggunian, which had ceased to exist. They also filed a “Petition on Appeal” directly with the RTC, bypassing the Joint Sanggunian. Bakun argued that these actions did not comply with Rule 40 of the Rules of Court, which requires the notice of appeal to be filed with the court that rendered the judgment.

The RTC and later the Court of Appeals ruled in favor of Sugpon, stating that the appeal was valid despite procedural irregularities. The Supreme Court upheld these rulings, emphasizing that:

“Rules of procedure are mere tools designed to facilitate the attainment of justice, and that strict and rigid application of rules which would result in technicalities that tend to frustrate rather than promote substantial justice must always be avoided.”

The Court noted that Sugpon’s Notice of Appeal was served on the Sangguniang Panlalawigan of Benguet, whose members were the same as those of the defunct Joint Sanggunian. Furthermore, Sugpon’s failure to furnish Bakun with a copy of the Notice of Appeal was deemed non-fatal, as Bakun still received notice and was able to participate in the proceedings.

Practical Implications

This ruling highlights the importance of procedural flexibility in boundary disputes. Local governments and individuals involved in such disputes should focus on ensuring that the essence of the appeal—communicating the intent to appeal and providing necessary information—is met, rather than strictly adhering to procedural formalities.

For those navigating similar disputes, it’s crucial to:

• Understand the specific requirements under the LGC and its IRR for appealing boundary dispute decisions.
• Ensure that the appeal process, while flexible, still communicates the intent to appeal clearly to all parties involved.
• Be prepared for potential procedural challenges and seek legal advice to navigate them effectively.

Key Lessons:

• Procedural flexibility can be crucial in ensuring justice in boundary disputes.
• Communication and clarity in the appeal process are more important than strict adherence to procedural formalities.
• Understanding the nuances of the LGC and its IRR can help in effectively appealing boundary dispute decisions.

Frequently Asked Questions

What is a boundary dispute?

A boundary dispute occurs when two or more local government units claim ownership over the same piece of land. These disputes are typically resolved under the Local Government Code of 1991.

What is the role of the Ad Hoc Joint Sanggunian in boundary disputes?

The Ad Hoc Joint Sanggunian is a special body formed by representatives from the local governments involved in the dispute. It aims to resolve the issue before it escalates to a court.

Can a party appeal a decision on a boundary dispute?

Yes, any party can appeal the decision of the sanggunian to the Regional Trial Court within the time and manner prescribed by the Rules of Court, as outlined in the Local Government Code and its IRR.

What should be included in a Notice of Appeal for a boundary dispute?

The Notice of Appeal should indicate the parties involved, the decision being appealed, and the reasons for the appeal. It should be served on the appropriate sanggunian or its equivalent.

What happens if there are procedural irregularities in the appeal process?

The Supreme Court has ruled that procedural irregularities should not automatically result in the dismissal of an appeal if the intent to appeal and the necessary information are communicated effectively.

How can I ensure my appeal in a boundary dispute is successful?

Ensure clear communication of your intent to appeal, provide all necessary information, and seek legal advice to navigate any procedural challenges effectively.

ASG Law specializes in local government and boundary dispute resolution. Contact us or email hello@asglawpartners.com to schedule a consultation.