Boundary Disputes and Local Government Authority: Caloocan v. Malabon

The Supreme Court recently settled an important question on how boundary disputes between local government units (LGUs) should be resolved. In City of Caloocan v. City of Malabon (G.R. No. 269159, November 4, 2024), the Court ruled that when two cities claim the same territory, the dispute must first be referred to their respective sanggunians for amicable settlement before any court action can proceed. This decision clarifies the proper procedure under the Local Government Code and prevents premature judicial intervention in territorial conflicts.

The Dispute Between Caloocan and Malabon

The controversy began when Republic Act No. 9019 converted the Municipality of Malabon into a highly urbanized city in 2001. The law defined Malabon's boundaries using specific geographic coordinates, and Caloocan claimed that portions of its Barangays 160 and 161 (including Libis and Baesa) were included within those boundaries.

Caloocan argued that this substantially altered its territorial jurisdiction without the plebiscite required by Article X, Section 10 of the Constitution. Residents of the affected barangays had long voted in Caloocan elections, paid real estate taxes there, and held titles issued by Caloocan's Registry of Deeds. Malabon, however, maintained that the disputed areas had always been part of its territory based on historical surveys and records.

The Issue Before the Court

The central question was whether the Court of Appeals erred in dismissing Caloocan's petition for declaratory relief, which sought to declare Section 2 of RA 9019 unconstitutional. The Court had to determine whether the case was properly a boundary dispute requiring the administrative procedure under the Local Government Code, or a constitutional challenge that could proceed directly to the courts.

The Supreme Court's Ruling

The Supreme Court denied Caloocan's petition and affirmed the Court of Appeals' dismissal. The Court held that the case was fundamentally a boundary dispute between two highly urbanized cities, regardless of how the parties framed their claims.

Under Section 118(d) of the Local Government Code, boundary disputes involving two or more highly urbanized cities must be jointly referred for settlement to the respective sanggunians of the parties. The Court emphasized that this procedure must be exhausted before resorting to judicial action. Only when the sanggunians fail to reach an amicable settlement within sixty days, or fail to decide the dispute within another sixty days, may the matter be elevated to the Regional Trial Court under Section 119.

The Court also found that the petition for declaratory relief was improper. Such petitions are available only before a breach or violation of the statute in question occurs. Since Malabon had already been exercising jurisdiction over the disputed areas, the controversy had ripened beyond a mere request for construction of the law.

The Plebiscite Question

While Caloocan argued that the absence of a plebiscite in the affected barangays made Section 2 of RA 9019 unconstitutional, the Court noted that this issue could not be resolved without first determining which city actually had territorial jurisdiction over the disputed areas. The conflicting claims of ownership and jurisdiction had to be settled first through the sanggunian procedure. Only after that factual determination could the question of whether a plebiscite was required be properly addressed.

Practical Takeaways

• Boundary disputes have a mandatory administrative procedure. LGUs cannot directly sue in court over territorial claims. They must first refer the dispute to their respective sanggunians for amicable settlement.

• The sanggunian procedure applies to all types of boundary conflicts. Whether the dispute involves a portion of territory or the whole area, if two LGUs claim the same land, the Local Government Code procedure applies.

• Courts are not the first stop for boundary conflicts. The Regional Trial Court only gets involved on appeal after the sanggunian process fails, and even then, its review is limited to determining the boundary lines as specified in the laws creating the LGUs.

• Declaratory relief has strict limits. A petition for declaratory relief is only available before a law has been breached or violated. Once the law is being enforced, other remedies must be pursued.

• The sanggunians cannot redraw boundaries. Any settlement reached must respect the boundary lines defined by law, as these reflect Congress's intent regarding each LGU's territorial jurisdiction.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.