Barangay Mayamot vs. Antipolo City

A Regional Trial Court has no original jurisdiction over boundary disputes between barangays in the same city or municipality; original jurisdiction lies with the Sangguniang Panlungsod or Sangguniang Bayan, and the RTC may only decide such disputes on appeal from the sanggunian's decision. This jurisdiction is determined by the material allegations of the complaint and the law in force at the time of the commencement of the action, regardless of the caption or designation of the action.

In 1984, the Batasang Pambansa enacted Batas Pambansa Bilang 787 to 794, creating eight new barangays in the then Municipality of Antipolo, namely: Beverly Hills, Dalig, Bagong Nayon, San Juan, Sta. Cruz, Munting Dilaw, San Luis, and Inarawan. These were added to the original eight barangays (Calawis, Cupang, Mambugan, Dela Paz, San Jose, San Roque, San Isidro, and Mayamot), bringing the total to sixteen. Each law contained provisions regarding the sitios comprising the new barangays, their boundaries, and mechanisms for ratification.

• Creation of New Barangays: In 1984, Batas Pambansa Bilang 787 to 794 were enacted, creating eight new barangays in the then Municipality of Antipolo: Beverly Hills, Dalig, Bagong Nayon, San Juan, Sta. Cruz, Munting Dilaw, San Luis, and Inarawan. These supplemented the original eight barangays (Calawis, Cupang, Mambugan, Dela Paz, San Jose, San Roque, San Isidro, and Mayamot), resulting in a total of sixteen barangays. Each creating law specified the sitios comprising the new barangays, their boundaries, and ratification mechanisms.
• Resolution No. 97-80: To integrate the territorial jurisdictions of the sixteen barangays, the Sangguniang Bayan of Antipolo passed Resolution No. 97-80, commissioning the City Assessor to plot and delineate territorial boundaries pursuant to Bureau of Lands Cadastral Survey No. 29-047 and the provisions of Batas Pambansa Bilang 787 to 794.
• Resolution No. 97-89: On October 25, 1989, the Sangguniang Bayan passed Resolution No. 97-89, "Defining the Territorial Boundaries of the Eight (8) Newly Created Barangays and the Eight (8) Former Existing Barangays of the Municipality of Antipolo, Rizal." The resolution approved the barangay boundaries specified and delineated in the plans and maps prepared by the City Assessor based on Cadastral Survey No. 29-047 and Batas Pambansa Nos. 787 to 794. The resolution recited that it was intended to avoid administrative conflicts and territorial encroachments, and cited Section 80 of Batas Pambansa 337 (Local Government Code of 1983) regarding settlement of boundary disputes.
• Allegations of Petitioner: On September 21, 1999, Barangay Mayamot filed a petition before the Regional Trial Court of Antipolo City for Declaration of Nullity and/or Annulment of Resolution No. 97-89 and Injunction. Barangay Mayamot alleged that while Batas Pambansa Bilang 787 to 794 did not require it to part with territory, Resolution No. 97-89 reduced its territory to one-half of its original area and apportioned portions to Barangays Sta. Cruz, Bagong Nayon, Cupang, and Mambugan. It further alleged that the preparation of the plan and adoption of the resolution were not preceded by consultation or public hearing, and that the resolution violated Section 82 of Batas Pambansa Bilang 337, which required an ordinance and plebiscite to create, alter, or modify barangay boundaries.
• RTC Findings: The trial court found that Resolution No. 97-89 was passed pursuant to the Cadastral Survey Plan approved by the Bureau of Lands and the creating laws, and was not intended to alter territorial boundaries. It concluded that the matter constituted a boundary dispute cognizable under the Local Government Code of 1983.

• Nature of the Action: Petitioner maintained that the action sought the nullity of Resolution No. 97-89 on the ground that it altered the territorial boundaries of Barangay Mayamot without complying with the requirements of Section 82 of Batas Pambansa Bilang 337, which mandated an ordinance and plebiscite for such alterations. It argued that the resolution drastically reduced its territory and lacked legal basis.
• Procedural Defects: Petitioner argued that the preparation of the boundary plans by the City Assessor and the adoption of Resolution No. 97-89 were not preceded by consultation or public hearing, rendering the resolution invalid.

• Jurisdictional Defect: Respondents countered that the action constituted a boundary dispute between barangays, over which the Regional Trial Court had no original jurisdiction under Republic Act No. 7160 (Local Government Code of 1991). They argued that Sections 118 and 119 of the LGC of 1991 vested original jurisdiction in the Sangguniang Panlungsod or Sangguniang Bayan, with the Regional Trial Court possessing only appellate jurisdiction.
• Nature of Resolution No. 97-89: Respondents maintained that Resolution No. 97-89 merely delineated existing boundaries pursuant to Batas Pambansa Bilang 787 to 794 and the approved Cadastral Survey No. 29-047, and did not purport to alter or modify territorial boundaries. Thus, the resolution was not subject to the plebiscite requirement under Section 82 of the LGC of 1983.

• Jurisdiction: Whether the Regional Trial Court had jurisdiction over the action filed by Barangay Mayamot.
• Nature of the Action: Whether the action constituted a boundary dispute cognizable by the Sangguniang Panlungsod under the Local Government Code of 1991, or a petition for nullity of a legislative act subject to the original jurisdiction of the Regional Trial Court.

• Jurisdiction: The Regional Trial Court lacked original jurisdiction over the action. Jurisdiction is determined by the material allegations of the complaint in relation to the law involved and the character of the reliefs prayed for, not by the caption or designation of the action. Despite being captioned as a petition for nullity of Resolution No. 97-89, the material allegations centered on the alleged inconsistency between Barangay Mayamot's perceived actual territory and its boundaries as defined and identified after the consolidation of the cadastral survey and the creating laws. This established a boundary dispute, defined as a situation where a portion or the whole of the territorial area of a Local Government Unit is claimed by two or more LGUs.
• Hierarchy of Remedies: Under Sections 118 and 119 of Republic Act No. 7160 (Local Government Code of 1991), boundary disputes involving two or more barangays in the same city or municipality shall be referred for settlement to the Sangguniang Panlungsod or Sangguniang Bayan concerned. If amicable settlement fails within sixty days, the sanggunian shall formally try and decide the dispute within sixty days from certification of failure. Only thereafter may the decision be appealed to the Regional Trial Court. The statute in force at the time of the commencement of the action (RA 7160) determines jurisdiction. Consequently, the Regional Trial Court lost its power to try boundary disputes at first instance, retaining only appellate jurisdiction.
• Nature of Resolution No. 97-89: Resolution No. 97-89 did not alter the territorial boundaries of Barangay Mayamot but merely delineated them in accordance with the Bureau of Lands Cadastral Survey No. 29-047 and Batas Pambansa Bilang 787 to 794. The resolution was passed to integrate the territorial jurisdictions of the old and newly created barangays, not to modify existing boundaries.

• Determination of Nature of Action — The nature of an action and the jurisdiction thereover are determined by the material allegations of the complaint in relation to the law involved and the character of the reliefs prayed for, regardless of the designation or caption used by the plaintiff. The caption is not controlling and is not even an indispensable part of the complaint.
• Jurisdiction in Boundary Disputes — Under the Local Government Code of 1991, the Sangguniang Panlungsod or Sangguniang Bayan possesses original jurisdiction to hear and decide boundary disputes between barangays in the same city or municipality. The Regional Trial Court's role is limited to appellate jurisdiction over decisions of the sanggunian. This jurisdiction is determined by the statute in force at the time of the commencement of the action.
• Boundary Dispute Defined — A boundary dispute exists when a portion or the whole of the territorial area of a Local Government Unit is claimed by two or more LGUs.
• Hierarchy of Remedies in Boundary Disputes — The procedure involves: (1) referral to the Sangguniang Panlungsod/Bayan for amicable settlement; (2) if settlement fails within 60 days, formal trial and decision by the sanggunian within 60 days from certification of failure; (3) appeal to the Regional Trial Court within the time and manner prescribed by the Rules of Court.

• "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." — Establishes the test for determining the nature of an action regardless of caption.
• "There is a boundary dispute when a portion or the whole of the territorial area of a Local Government Unit (LGU) is claimed by two (2) or more LGUs." — Definition of boundary dispute.
• "As we have ruled in the cases of Municipality of Sta. Fe v. Municipality of Aritao, and Municipality of Pateros v. Court of Appeals, by virtue of the Local Government Code of 1991, the RTC lost its power to try, at the first instance, cases of boundary disputes, and it is only when the intermediary steps have failed that resort to the RTC will follow as provided in the laws." — Affirms the statutory allocation of jurisdiction between local legislative bodies and the judiciary.

• Municipality of Sta. Fe v. Municipality of Aritao, G.R. No. 140474, September 21, 2007, 533 SCRA 586 — Followed; established that under the LGC of 1991, the RTC lost its original jurisdiction over boundary disputes and exercises only appellate jurisdiction.
• Municipality of Pateros v. Court of Appeals, G.R. No. 157714, June 16, 2009, 589 SCRA 130 — Followed; reaffirmed the hierarchy of remedies in boundary disputes and the limited appellate role of the RTC.

• Section 82, Batas Pambansa Bilang 337 (Local Government Code of 1983) — Cited by petitioner; provided that alteration, modification, and definition of barangay boundaries shall be by ordinance and confirmed by a majority of votes cast in a plebiscite. The Court distinguished Resolution No. 97-89 as not being an ordinance altering boundaries but merely delineating existing ones.
• Sections 118-119, Republic Act No. 7160 (Local Government Code of 1991) — Applied; vested original jurisdiction over boundary disputes between barangays in the Sangguniang Panlungsod or Sangguniang Bayan, and appellate jurisdiction in the Regional Trial Court.
• Rule III, Article 15, Rules and Regulations Implementing the Local Government Code of 1991 (Administrative Order No. 270) — Cited; defines a boundary dispute as when a portion or whole of the territorial area of an LGU is claimed by two or more LGUs.

Velasco, Jr., (Chairperson), Peralta, Perez, and Reyes, JJ.