In a dispute over Liwagao Island, the Supreme Court clarified the process for resolving territorial jurisdiction conflicts between local government units. The Court ruled that while the Regional Trial Court (RTC) had jurisdiction due to a deadlock at the Sangguniang Panlalawigan level, the case indeed constituted a boundary dispute as defined by the Local Government Code. This decision highlights the importance of exhausting administrative remedies before resorting to judicial intervention, ensuring that boundary disputes are first addressed by the concerned local legislative bodies.

Liwagao Island: Whose Turf Is It Anyway?

The case of Province of Antique and Municipality of Caluya v. Hon. Recto A. Calabocal, et al., G.R. No. 209146, revolves around a territorial contention over Liwagao Island, a 114-hectare landmass situated between the Province of Antique and the Province of Oriental Mindoro. This disagreement led the respondents, the Province of Oriental Mindoro and the Municipality of Bulalacao, to file a petition for “Recovery and Declaration of Political Jurisdiction/Dominion and Mandamus” with the Regional Trial Court (RTC) of Roxas, Oriental Mindoro. Petitioners, the Province of Antique and the Municipality of Caluya, questioned the RTC’s jurisdiction, arguing that the dispute should first be resolved by the Sangguniang Panlalawigans of both provinces.

The heart of the matter lies in the interpretation of Section 118 of the Local Government Code, which outlines the jurisdictional responsibility for settling boundary disputes among local government units. Petitioners contended that the RTC prematurely assumed jurisdiction, as the Sangguniang Panlalawigans of Antique and Oriental Mindoro should have been given the initial opportunity to resolve the issue jointly. This contention stems from the belief that the dispute falls squarely within the ambit of a boundary dispute as contemplated by the Local Government Code.

Respondents, on the other hand, argued that their petition before the RTC was not merely an appeal from a failed settlement but an original action to recover jurisdiction and dominion over Liwagao Island. They posited that the RTC’s intervention was justified because the Sangguniang Panlalawigan of Antique had already expressed its unwillingness to engage in any form of settlement, rendering further administrative proceedings futile. Respondents claimed that they previously lent the administration of the island and now wanted it back.

The Supreme Court, in analyzing the case, underscored the definition of a boundary dispute as articulated in the Implementing Rules and Regulations (IRR) of the Local Government Code, specifying that such a dispute arises when “a portion or the whole of the territorial area of an LGU is claimed by two or more LGUs.”

RULE III
Settlement of Boundary Disputes

ARTICLE 15. Definition and Policy. — There is a boundary dispute when a portion or the whole of the territorial area of an LGU is claimed by two or more LGUs. Boundary disputes between or among LGUs shall, as much as possible, be settled amicably.

The Court acknowledged that the dispute indeed fell under the definition of boundary dispute, but emphasized that the RTC’s exercise of jurisdiction was warranted due to the specific circumstances of the case. Because the Province of Antique preemptively refused to engage in settlement talks, the respondents’ decision to seek judicial recourse was deemed appropriate. The Court affirmed that the RTC has jurisdiction over the dispute, but that the case involves a boundary dispute.

Despite recognizing that the case involved a boundary dispute, the Supreme Court upheld the RTC’s jurisdiction, primarily because the petitioners themselves had frustrated the process of amicable settlement at the Sangguniang Panlalawigan level. The Court emphasized that the procedure for resolving boundary disputes, as outlined in the Local Government Code, envisions a collaborative effort between the concerned local government units.

The Supreme Court underscored the importance of adhering to the procedures outlined in the Local Government Code for resolving boundary disputes. However, the Court also recognized that strict adherence to these procedures may be excused when one party demonstrates an unwillingness to engage in good-faith negotiations. The Court’s decision serves as a reminder that local government units must act in a manner that promotes amicable settlement and cooperation in resolving territorial disputes.

The Court articulated that while the legislative councils of the contending local government units typically have jurisdiction over their boundary disputes, this jurisdiction is contingent upon the willingness of both parties to engage in good-faith negotiations. When one party refuses to participate in such negotiations, the other party may be justified in seeking judicial intervention to protect its territorial claims.

This decision reinforces the principle that boundary disputes should ideally be resolved through amicable means at the local government level. However, it also recognizes that judicial intervention may be necessary when one party obstructs the process of amicable settlement, leaving the other party with no other recourse to protect its territorial interests.

FAQs

What was the key issue in this case?	The central issue was whether the RTC had jurisdiction over a dispute between the Province of Antique and the Province of Oriental Mindoro regarding territorial jurisdiction over Liwagao Island.
What is a boundary dispute according to the Local Government Code?	A boundary dispute exists when a portion or the whole of the territorial area of a local government unit (LGU) is claimed by two or more LGUs, as defined in the Implementing Rules and Regulations of the Local Government Code.
What is the initial step in resolving boundary disputes between LGUs?	Boundary disputes should first be settled amicably by the Sanggunians (legislative councils) of the concerned local government units before resorting to judicial intervention.
When can a party appeal a boundary dispute to the Regional Trial Court (RTC)?	A party can appeal to the RTC only after the Sanggunians have failed to reach an amicable settlement and have formally decided the issue, as stipulated in Section 119 of the Local Government Code.
What was the RTC’s role in this case?	The RTC initially assumed jurisdiction over the case, which was questioned by the Province of Antique, arguing that the dispute should first be resolved by the Sangguniang Panlalawigans of both provinces.
Why did the Supreme Court uphold the RTC’s jurisdiction despite the required initial steps?	The Supreme Court upheld the RTC’s jurisdiction because the Province of Antique refused to engage in any form of settlement, making it impossible for the respondents to follow the procedure outlined in the Local Government Code.
What was the effect of the Province of Antique’s refusal to engage in settlement talks?	The refusal effectively blocked any way to continue following the steps in the Implementing Rules and Regulations, justifying the respondents’ decision to seek judicial recourse.
What is the main takeaway from this Supreme Court decision?	The decision underscores the importance of exhausting administrative remedies before resorting to judicial intervention in boundary disputes, but also acknowledges that judicial recourse is available when one party obstructs the amicable settlement process.

Ultimately, this case serves as a guide for local government units encountering territorial disputes, emphasizing the necessity of adhering to the procedures outlined in the Local Government Code while also recognizing the exceptions that may warrant judicial intervention. The decision seeks to balance the principles of local autonomy and efficient dispute resolution, ensuring that territorial conflicts are addressed in a fair and timely manner.

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: PROVINCE OF ANTIQUE AND MUNICIPALITY OF CALUYA VS. HON. RECTO A. CALABOCAL, JUDGE-DESIGNATE, REGIONAL TRIAL COURT, BRANCH 43, ROXAS, ORIENTAL MINDORO, PROVINCE OF ORIENTAL MINDORO, AND MUNICIPALITY OF BULALACAO, G.R. No. 209146, June 08, 2016