The Supreme Court ruled that when some local government units (LGUs) refuse to participate in legally mandated settlement procedures for boundary disputes, the initiating LGU can seek judicial recourse. This decision clarifies that inaction from involved parties cannot prevent an LGU from asserting its territorial claims in court, ensuring that disputes are resolved and that LGUs are not left without legal remedies. This balances the need for amicable settlements with the right to judicial intervention when cooperation fails.

Boundary Lines and Uncooperative Neighbors: Can Pateros Claim Its Territory?

The Municipality of Pateros has been in a long-standing territorial dispute with the Cities of Taguig and Makati over portions of Fort Bonifacio. This case examines Pateros’ attempt to reclaim land it asserts historically belongs to it, specifically Parcel 4 of Survey Plan Psu-2031. The legal question revolves around whether Pateros can directly sue in court, given that the Local Government Code (LGC) mandates that boundary disputes should first be settled amicably among the involved local government units (LGUs) — in this instance, through their respective sanggunians (councils).

The heart of the matter lies in interpreting Sections 118 and 119 of the Local Government Code, which outline the process for settling boundary disputes. These sections emphasize amicable settlements, with disputes first referred to the sanggunians of the LGUs involved. Specifically, Section 118 states:

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:

(d) Boundary disputes involving a component city or municipality on the one hand and a highly urbanized city on the other, or two (2) or more highly urbanized cities, shall be jointly referred for settlement to the respective sanggunians of the parties.

(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.

However, Taguig’s consistent failure to respond to Pateros’ invitations for dialogue complicated matters significantly. Pateros argued that it had exhausted all efforts to engage in amicable settlement, but Taguig’s refusal to participate made it impossible to comply fully with the LGC’s requirements. Makati, initially open to dialogue, acknowledged that settlement was impossible due to its own ongoing dispute with Taguig. The key issue then became whether Taguig’s inaction justified Pateros’ decision to file a direct court action.

The Supreme Court examined whether Pateros had sufficiently complied with the requirements of Sections 118(d) and (e) of the LGC and Rule III of its Implementing Rules and Regulations (IRR). The court found that Pateros’ actions, while intended to initiate dialogue, fell short of the joint referral and exercise of jurisdiction envisioned by the LGC. Specifically, the court noted that the absence of a joint resolution and formal trial involving all three sanggunians indicated a procedural lapse.

Despite this procedural deficiency, the Supreme Court acknowledged the difficult position Pateros found itself in due to Taguig’s non-responsiveness. The court drew a parallel to the case of Province of Antique v. Judge Calabocal, where one LGU’s explicit refusal to engage in settlement talks justified the other LGU’s decision to seek judicial intervention. While Taguig’s inaction differed from Antique’s explicit refusal, the court recognized that both scenarios effectively prevented the amicable settlement process from proceeding as intended by the LGC.

The court emphasized that it would be unjust to penalize Pateros for failing to comply with procedures made impossible by Taguig’s uncooperative stance. To hold otherwise would leave Pateros without a legal remedy to assert its territorial claims, creating an unacceptable situation of uncertainty. Therefore, the Supreme Court concluded that Pateros was justified in pursuing judicial recourse, and that the Regional Trial Court (RTC) had jurisdiction over the dispute, treating the case as an original action rather than an appeal under Section 119 of the LGC.

The Supreme Court also addressed the potential implications of its prior ruling in G.R. No. 235316, which resolved the territorial dispute between Makati and Taguig. The court clarified that the finality of that decision did not constitute res judicata (a matter already judged) that would preclude Pateros from pursuing its claims. While there was some overlap in the subject matter, the court emphasized that Pateros was not a party to the earlier case and had not yet had an opportunity to present its own evidence to support its historical claim to the disputed area.

The principle of res judicata did not apply due to a lack of identity of parties and causes of action. Pateros had the right to present its case independently. However, the court noted that with the ruling in G.R. No. 235316, which placed Fort Bonifacio outside Makati’s jurisdiction, Pateros might no longer need to maintain its suit against Makati, except perhaps to seek an accounting of proceeds received by Makati while exercising jurisdiction over the area.

FAQs

What was the key issue in this case?	The central issue was whether the Municipality of Pateros could directly file a court case to resolve a territorial dispute with Taguig and Makati, despite failing to fully comply with the Local Government Code’s mandated amicable settlement procedures. This was due to Taguig’s lack of cooperation.
What is the Local Government Code’s requirement for boundary disputes?	The LGC requires that boundary disputes between local government units be settled amicably through their respective sanggunians (councils) before resorting to court action. This process involves joint referrals and attempts at settlement within a specified timeframe.
Why did Pateros file a direct court action?	Pateros filed a direct court action because Taguig consistently failed to respond to invitations for dialogue, making it impossible to comply fully with the LGC’s amicable settlement procedures. Pateros argued that it had exhausted all efforts to engage in settlement.
How did the Supreme Court rule on the issue of jurisdiction?	The Supreme Court ruled that the Regional Trial Court had jurisdiction over the dispute. It emphasized that Taguig and Makati could not insist that Pateros strictly observe procedures they themselves had made impossible to follow through inaction.
What is res judicata, and why didn’t it apply in this case?	Res judicata is a legal principle that prevents the same parties from relitigating issues already decided in a prior case. It did not apply because Pateros was not a party to the previous case between Makati and Taguig and had not yet had an opportunity to present its own evidence.
What was the significance of the Province of Antique v. Judge Calabocal case?	The Supreme Court cited Province of Antique v. Judge Calabocal, where one LGU’s explicit refusal to engage in settlement justified the other LGU’s decision to seek judicial intervention. This established a precedent for allowing judicial recourse when amicable settlement efforts are frustrated by non-cooperation.
Does this ruling mean Pateros automatically wins its territorial claim?	No, this ruling only means that Pateros has the right to have its case heard in court. The court will still need to evaluate the evidence presented by all parties to determine the validity of Pateros’ territorial claim.
What is the practical implication of this ruling for other LGUs in boundary disputes?	This ruling clarifies that LGUs cannot frustrate the territorial claims of other LGUs by simply refusing to participate in settlement procedures. Inaction or non-cooperation can open the door to judicial intervention, ensuring that disputes are resolved and LGUs are not left without legal remedies.

In conclusion, the Supreme Court’s decision underscores the importance of balancing the preference for amicable settlements with the need for effective legal remedies in boundary disputes. This case provides a crucial clarification that inaction or non-cooperation from one LGU cannot prevent another LGU from seeking judicial resolution of its territorial claims, ensuring that such disputes can be resolved fairly and efficiently.

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 Pateros vs. City of Taguig and City of Makati, G.R. No. 220824, April 19, 2023