Boundary Disputes Between Municipalities: Who Has Jurisdiction?

When two municipalities fight over territory, a critical question arises: which government body has the legal authority to resolve the conflict? In Municipality of Sta. Fe v. Municipality of Aritao (G.R. No. 140474, September 21, 2007), the Supreme Court settled this issue, ruling that under the Local Government Code of 1991, the Sangguniang Panlalawigan—not the trial courts—has original jurisdiction over municipal boundary disputes. This decision clarifies the proper forum for such cases and the limits of judicial intervention.

The Facts of the Case

In 1980, the Municipality of Sta. Fe filed a case before the Regional Trial Court (RTC) of Bayombong, Nueva Vizcaya, seeking the determination of a boundary dispute involving two barangays. At that time, the governing law—Section 2167 of the Revised Administrative Code, as amended by Republic Act No. 6128—gave the Court of First Instance (now the RTC) jurisdiction to hear and decide municipal boundary disputes.

The trial proceeded for years. However, in 1988, the court suspended proceedings and referred the case to the Sangguniang Panlalawigan for possible amicable settlement, as required by law. The Sanggunian later adopted a resolution declaring the disputed barangays part of the respondent municipality's territory, but it also endorsed the case back to the RTC for further proceedings.

In 1992, the respondent moved to dismiss the case for lack of jurisdiction, citing the Supreme Court's ruling in Municipality of Sogod v. Rosal and the enactment of the Local Government Code of 1991. The RTC granted the motion, and the Court of Appeals affirmed. Sta. Fe appealed to the Supreme Court.

The Issue

The central question was whether the RTC still had jurisdiction over a boundary dispute case that was filed before the effectivity of the Local Government Code of 1991, given that the new law transferred original jurisdiction over such disputes to the Sangguniang Panlalawigan.

The Ruling

The Supreme Court denied the petition and upheld the dismissal. The Court traced the history of the law on municipal boundary disputes, noting that the 1991 Code introduced a major change: the Sangguniang Panlalawigan is now vested with original jurisdiction to actually hear and decide the dispute, not merely to assist in amicable settlement.

Under Section 118 of the Local Government Code, boundary disputes between municipalities within the same province shall be referred to the Sangguniang Panlalawigan for settlement. If no amicable settlement is reached within 60 days, the Sanggunian must formally try and decide the case. Under Section 119, any party may appeal the Sanggunian's decision to the proper RTC, which then exercises appellate jurisdiction.

Why the Court Applied the New Law Retroactively

The Court acknowledged the general rule that once a court has acquired jurisdiction over a case, its jurisdiction is not affected by new legislation transferring jurisdiction to another body. However, it recognized an exception: a law may operate on pending cases if it expressly provides for retroactivity or if retroactivity is necessarily implied.

The Court found that the 1987 Constitution and the Local Government Code of 1991 were intended to apply immediately to all existing political units, including those with pending cases. The overarching policy was to empower local government units without delay. Moreover, the Court noted that no substantial prejudice resulted from the retroactive application because the RTC could still review the Sanggunian's decision on appeal.

Practical Takeaways

• Original jurisdiction over municipal boundary disputes now lies with the Sangguniang Panlalawigan, not the trial courts.
• The RTC's role is appellate, not original, in these disputes—it reviews the Sanggunian's decision on appeal.
• Filing a boundary dispute directly with the RTC after the Local Government Code of 1991 took effect will likely result in dismissal for lack of jurisdiction.
• The 1991 Code applies even to cases pending before its enactment, provided no vested rights are impaired.
• A decision rendered by a court without jurisdiction is a nullity and may be challenged at any stage of the proceedings.

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