257_brgy. Mayamot V. Antipolo City (2016)_collera.docx

Brgy. Mayamot v. Antipolo City | G.R. No. 187349 | August 17, 2016 | Jardeleza, J. Petitioner: Brgy. Mayamot, Antipolo City Respondents: Antipolo City, Sangguniang Panglungsod of Antipolo, Brgys. Sta. Cruz, Bagong Nayon, Cupang, and Mambugan, City Assessor, and City Treasurer of Antipolo SUMMARY: Congress passed several laws creating 8 new barangays in Antipolo. The Sangguniang Bayan of Antipolo then passed Resolution No. 97-89, which apportioned the new boundaries of all the barangays pursuant to the new laws. Half of Brgy. Mayamot’s territory was apportioned through the resolution to respondent barangays, so it filed a petition to annul said resolution. The SC dismissed the case, ruling that the RTC does not have original jurisdiction to try barangay boundary disputes. DOCTRINE: According to Secs. 118 and 119 of the LGC, boundary disputes between barangays in the same city or municipality must first be referred for settlement to the sangguniang panglungsod or sangguniang bayan concerned. In case of failure of amicable settlement, the dispute shall be formally tried by the sanggunian concerned. The sanggunian’s decision may then be appealed to the RTC. Thus, the RTC only exercises appellate, not original, jurisdiction over the case at bar. FACTS: 

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1984: BP Blg. 787 to 794 were passed, creating 8 new barangays in the then-Municipality of Antipolo. With the addition of these new barangays, Antipolo became composed of 16 barangays in total. o Pursuant to these laws, respondent Sangguniang Bayan of Antipolo passed Resolution No. 97-80, commissioning respondent City Assessor to plot the territories of all 16 barangays. o Later, the Sanggunian passed Resolution No. 97-89, delineating these barangays’ boundaries based on the maps prepared by the City Assessor. Sept. 21, 1999: Petitioner Brgy. Mayamot (one of the 8 original barangays before the BPs were enacted) filed a Petition for Declaration of Nullity and/or Annulment of Resolution No. 97-89 and Injunction against respondents before RTC Antipolo. It alleged that: o While the BPs did not require it to part with any of its territory, Resolution No. 97-89 reduced its territory to half of its original area (the other half was apportioned to respondent barangays); o The City Assessor’s plan and the Sanggunian’s adoption of the resolution were done without public consultation; o Resolution No. 97-89 violated Sec. 82 of the LGC of 1983 (which was in force at the time it was passed), which stated that alteration, modification, and definition of boundaries shall be by ordinance and confirmed by a majority of the votes cast in a plebiscite called for that purpose. Aug. 1, 2006: RTC Antipolo dismissed the petition, ruling that the case was actually a boundary dispute which should have been ventilated in accordance with the remedies under the LGC of 1983. Jan. 30, 2009: CA affirmed RTC, ruling that the LGC of 1991 applies to the case at bar since it was already in effect at the time the petition was filed. In any case, Secs. 118 and 119 of the LGC explicitly provide that the RTC had no original jurisdiction to settle barangay boundary disputes.

ISSUES + RULING: 1. W/N the RTC and CA erred in dismissing the case for lack of jurisdiction. NO. 

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The nature of an action and its subject matter, as well as which court of agency has jurisdiction over the same, are determined by the material allegations of the complaint, in relation to the applicable law and the reliefs prayed for. o The fact that the petition is captioned as one seeking the annulment of Resolution No. 97-89 is of no moment. Brgy. Mayamot is in effect claiming territory which was apportioned to respondent barangays by virtue of said resolution. Thus, it is a boundary dispute between Brgy. Mayamot and respondents. Under the LGC of 1991, the RTC has no original jurisdiction over barangay boundary disputes. It only exercises appellate jurisdiction in case of failure of amicable settlement. o Section 118, LGC. Jurisdictional Responsibility for Settlement of Boundary Dispute. - Boundary disputes between and among local government units shall, as much as possible, be settled amicably. To this end: (a) Boundary disputes involving two (2) or more barangays in the same city or municipality shall be referred for settlement to the sangguniang panlungsod or sangguniang bayan concerned. x x x (e) In the event the sanggunian fails to effect an amicable settlement within sixty (60) days from the date the dispute was referred thereto, it shall issue a certification to that effect. Thereafter, the

dispute shall be formally tried by the sanggunian concerned which shall decide the issue within sixty (60) days from the date of the certification referred to above. o Section 119, LGC. Appeal. - Within the time and manner prescribed by the Rules of Court, any party may elevate the decision of the sanggunian concerned to the proper Regional Trial Court having jurisdiction over the area in dispute. The Regional Trial Court shall decide the appeal within one (1) year from the filing thereof. Pending final resolution of the disputed area prior to the dispute shall be maintained and continued for all legal purposes. DISPOSITION: Petition dismissed.