G.R. No. 235316, December 01, 2021
Municipality of Makati (now City of Makati), Petitioner, vs. Municipality of Taguig (now City of Taguig), Respondent.

FACTS

On November 22, 1993, the Municipality of Taguig filed a Complaint before the RTC of Pasig against the City of Makati and other government officials, docketed as Civil Case No. 63896. The complaint sought judicial confirmation of Taguig’s territory and boundary limits and a declaration of unconstitutionality of certain provisions of Presidential Proclamations Nos. 2475 (1986) and 518 (1990). The dispute arose from conflicting claims over the areas comprising the Enlisted Men’s Barangays (EMBOs) and the entirety of Fort Andres Bonifacio (Fort Bonifacio), formerly Fort William McKinley (Fort McKinley).
Taguig’s claim was based on historical and documentary evidence. It asserted that it had existed for over 400 years and that Fort McKinley, established by the US Government in 1902 on portions of Hacienda Maricaban, was mainly situated in Taguig. It relied on Survey Plan Psu-2031, which divided Fort McKinley into parcels and indicated its location in Pasay, Parañaque, Taguig, and Pasig, but not Makati. Taguig also presented its approved Cadastral Mapping (MCadm 590-D) from 1983, which included all of Fort Bonifacio and conformed with the maps of adjoining LGUs, excluding the disputed areas from their territories. It further cited Special Patents issued in 1995, which described the conveyed lands as situated in Taguig.
Makati claimed the disputed areas were part of Hacienda Maricaban, which fell under several towns, including San Pedro Macati. It argued that the portion sold in 1902, which included Fort McKinley, was within San Pedro Macati’s territory. Makati relied on a sketch plan from its expert witness showing Fort McKinley lay outside the property registered under OCT No. 291 (from Doña Casal) and was located to its north. It also referenced a 1907 map from the US National Archives.

ISSUE

The core issue was which local government unit—Makati or Taguig—has territorial jurisdiction over the disputed areas comprising the EMBOs and Fort Bonifacio.

RULING

The Supreme Court denied Makati’s petition and affirmed the CA resolutions which upheld the RTC’s decision in favor of Taguig. The Court ruled that Taguig presented clear, consistent, and convincing preponderance of evidence to establish its jurisdiction over the disputed areas.
The Court emphasized that in boundary disputes, the burden of proof rests on the plaintiff (Taguig) to establish its claim by a preponderance of evidence. It found that Taguig successfully discharged this burden through a combination of historical evidence, official government maps, and documentary titles. Key evidence included:
1. Survey Plan Psu-2031 (1909): This plan, approved by the Director of Lands, showed Fort McKinley was situated in Pasay, Parañaque, Taguig, and Pasig, with no mention of Makati.
2. Proclamation No. 423 (1957): This proclamation by President Garcia establishing Fort Bonifacio stated it was located in Pasig, Taguig, Parañaque, and Pasay—again, not Makati.
3. Cadastral Maps: Taguig’s MCadm 590-D (approved 1983) included Fort Bonifacio and conformed with the adjoining LGUs’ maps, which excluded the area. In contrast, Makati’s MCadm 571-D (approved 1979) did not include the military barangays (EMBOs) and indicated that past San Jose Creek was Fort Bonifacio under Taguig’s cadastral case.
4. Special Patents and Titles: Special Patent Nos. 3595 and 3596 (1995) and the resulting OCT described the lands as situated in Taguig.
5. Historical Recognition: The Court noted that for decades, national government agencies and other entities had recognized Taguig’s jurisdiction over Fort Bonifacio in official documents.
The Court found Makati’s evidence insufficient and inconsistent. Its claim relied heavily on the 1902 deed of sale referencing “San Pedro Macati,” but failed to conclusively prove that the territorial jurisdiction of the estate named “San Pedro Macati” was co-extensive with the present-day City of Makati. The sketch plan and 1907 map presented by Makati’s witness were not officially approved survey plans and could not prevail over the approved Psu-2031. The Court also held that Presidential Proclamations 2475 and 518, which created the barangays within the disputed areas and placed them under Makati’s administration, were void for altering Taguig’s boundaries without the required plebiscite under the Constitution.
Therefore, the Supreme Court declared that the disputed areas, comprising the EMBOs and Fort Bonifacio, are part of the territory of Taguig.