The Supreme Court has affirmed the principle that boundary disputes between barangays within the same city or municipality fall under the original jurisdiction of the Sangguniang Panlungsod or Sangguniang Bayan, not the Regional Trial Court (RTC). This means that if a barangay believes its territory has been wrongly reduced or altered, it must first seek resolution from the local legislative body before elevating the matter to the RTC. This decision underscores the importance of adhering to the procedural hierarchy established by the Local Government Code in resolving boundary disputes, ensuring that local governing bodies play a central role in settling disagreements within their jurisdiction.

When Mapping Errors Spark Territorial Disputes: Who Decides Barangay Boundaries?

The case of Barangay Mayamot v. Antipolo City arose from a disagreement over the territorial boundaries of several barangays in Antipolo City. In 1984, Batas Pambansa Bilang (BP Blg.) 787 to 794 created eight new barangays within the municipality. To integrate these new territories, the Sangguniang Bayan of Antipolo commissioned the City Assessor to delineate the boundaries of all sixteen barangays, resulting in Resolution No. 97-89. Barangay Mayamot contested this resolution, claiming it reduced their territory and apportioned it to neighboring barangays, namely Sta. Cruz, Bagong Nayon, Cupang, and Mambugan. The central legal question became whether the RTC had the authority to hear this dispute in the first instance, or whether the matter should have been addressed by the local legislative body.

Barangay Mayamot argued that Resolution No. 97-89 violated Section 82 of the Local Government Code of 1983 (BP Blg. 337), which required an ordinance and a plebiscite to alter barangay boundaries. They claimed the resolution effectively modified their territory without proper legal basis or public consultation. However, the RTC and the Court of Appeals both dismissed the petition, asserting that the resolution was merely an implementation of existing laws (BP Blg. 787 to 794) and the cadastral survey, not an alteration of boundaries. Crucially, they highlighted that the case was essentially a boundary dispute, which, under Republic Act No. 7160 (RA No. 7160), the Local Government Code of 1991, falls under the jurisdiction of the Sangguniang Panlungsod or Sangguniang Bayan.

The Supreme Court affirmed the lower courts’ decisions, emphasizing that the nature of an action is determined by the allegations in the complaint and the reliefs sought, not merely by its designation or caption. The Court stated that:

Jurisdiction is defined as the power and authority of the courts to hear, try and decide cases. The nature of an action and its subject matter, as well as which court or agency of the government has jurisdiction over the same, are determined by the material allegations of the complaint in relation to the law involved and the character of the reliefs prayed for, whether or not the complainant/plaintiff is entitled to any or all of such reliefs.

In this context, the Court found that Barangay Mayamot’s claims centered on an alleged inconsistency between their perceived territory and the boundaries defined by the cadastral survey and Resolution No. 97-89. This, the Court reasoned, constituted a boundary dispute, defined as:

…when a portion or the whole of the territorial area of a Local Government Unit (LGU) is claimed by two (2) or more LGUs.

The critical provision guiding the court’s decision was Section 118 of RA No. 7160, which stipulates the process for settling boundary disputes. It prioritizes amicable settlement at the local level. According to Section 118:

Section 118. 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.

The law mandates that the Sangguniang Panlungsod or Sangguniang Bayan must first attempt to facilitate an amicable settlement. If this fails, the sanggunian then formally tries the dispute and renders a decision. Only after these steps are exhausted can the decision be appealed to the RTC. The Supreme Court emphasized that this procedural framework reflects a clear legislative intent to empower local government units to resolve territorial disagreements within their jurisdictions.

The Supreme Court’s ruling reinforces the importance of adhering to the jurisdictional hierarchy established in RA No. 7160. It clarifies that boundary disputes between barangays must initially be addressed by the Sangguniang Panlungsod or Sangguniang Bayan. This approach contrasts with allowing direct recourse to the RTC, which would undermine the role of local governance in resolving such disputes. Moreover, the ruling highlights the principle that the substance of a complaint, rather than its label, determines the appropriate forum for its resolution. Even if a case is framed as a challenge to the validity of a resolution, if the underlying issue is a boundary dispute, the procedures outlined in RA No. 7160 must be followed.

This decision carries significant practical implications for local government units. It clarifies the proper venue and procedure for resolving boundary disputes, preventing unnecessary litigation and ensuring that local voices are heard in the resolution process. By emphasizing the role of the Sangguniang Panlungsod or Sangguniang Bayan, the ruling promotes local autonomy and empowers local governments to manage their own affairs. The ruling also serves as a reminder of the importance of accurate cadastral surveys and clear delineation of boundaries to prevent future disputes. LGUs should invest in maintaining up-to-date maps and records to minimize the potential for territorial disagreements.

FAQs

What was the key issue in this case?	The central issue was whether the Regional Trial Court (RTC) had jurisdiction over a boundary dispute between barangays in Antipolo City, or if the dispute should have been initially resolved by the Sangguniang Panlungsod.
What is a boundary dispute according to the Supreme Court?	A boundary dispute occurs when one Local Government Unit (LGU) claims a portion or the whole of the territorial area of another LGU, leading to a disagreement over jurisdiction and resources.
What law governs the settlement of boundary disputes between barangays?	Republic Act No. 7160 (RA No. 7160), also known as the Local Government Code of 1991, specifically Sections 118 and 119, outlines the procedures for resolving boundary disputes between LGUs.
What is the role of the Sangguniang Panlungsod or Sangguniang Bayan in resolving boundary disputes?	The Sangguniang Panlungsod or Sangguniang Bayan is primarily responsible for amicably settling boundary disputes between barangays within their jurisdiction and has the original jurisdiction to formally hear and decide the dispute if amicable settlement fails.
Can a decision of the Sangguniang Panlungsod or Sangguniang Bayan be appealed?	Yes, the decision of the Sangguniang Panlungsod or Sangguniang Bayan can be appealed to the Regional Trial Court (RTC) having jurisdiction over the area in dispute, within the time and manner prescribed by the Rules of Court.
What was Barangay Mayamot’s main argument in the case?	Barangay Mayamot argued that Resolution No. 97-89 illegally altered their territory without following the proper procedure outlined in the Local Government Code of 1983, which required an ordinance and a plebiscite.
Why did the Supreme Court rule against Barangay Mayamot?	The Supreme Court ruled against Barangay Mayamot because the core issue was a boundary dispute, which RA No. 7160 designates to be resolved first by the Sangguniang Panlungsod, not the RTC in the first instance.
What is the significance of this ruling for other local government units?	The ruling clarifies the proper procedure for resolving boundary disputes, emphasizing the primary role of local legislative bodies, promoting local autonomy, and preventing unnecessary litigation by directing parties to exhaust local remedies first.

In conclusion, the Supreme Court’s decision in Barangay Mayamot v. Antipolo City reaffirms the importance of adhering to the Local Government Code in resolving territorial disputes between barangays. By requiring initial recourse to the Sangguniang Panlungsod or Sangguniang Bayan, the ruling empowers local governments to manage their own affairs and promotes efficient dispute resolution at the grassroots level.

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 Mayamot v. Antipolo City, G.R. No. 187349, August 17, 2016