G.R. No. 224335, March 02, 2020
Municipality of Bakun, Benguet, herein represented by its Municipal Mayor Hon. Fausto T. Labinio, Petitioner, vs. Municipality of Sugpon, Ilocos Sur, herein represented by its Municipal Mayor Hon. Fernando C. Quiton, Sr., Respondent.

FACTS

The Municipalities of Bakun, Benguet and Sugpon, Ilocos Sur both claimed a 1,118-hectare parcel of land. Pursuant to the Local Government Code (LGC) on boundary disputes, the issue was referred to an Ad Hoc Joint Sanggunian of the Provinces of Benguet and Ilocos Sur. The Joint Sanggunian, voting 4-3, issued Joint Resolution No. 1, Series of 2014, adjudging the land to Bakun. Aggrieved, the Province of Ilocos Sur, through the Municipality of Sugpon, served a Notice of Appeal to the Sangguniang Panlalawigan of the Province of Benguet. Subsequently, Sugpon filed a “Petition on Appeal” with the Regional Trial Court (RTC) of Ilocos Sur. Bakun moved to dismiss the appeal, arguing that the Notice of Appeal failed to comply with Rule 40 of the Revised Rules of Court because it was not filed with the Joint Sanggunian that rendered the resolution, was served on an improper party, lacked essential particulars, and docket fees were not paid. The RTC denied the motion, ruling that Rule 40 was not strictly applicable and that the LGC merely mandated the “filing of any appropriate pleading,” which Sugpon complied with. The Court of Appeals affirmed the RTC, holding that appeals in boundary disputes are within RTC jurisdiction and governed by Rule 40, and that Sugpon had complied with the requirements. Bakun filed the present petition, arguing that Sugpon lost its right to appeal due to non-compliance with Rule 40, rendering the Joint Resolution final and executory.

ISSUE

Did Sugpon’s appeal comply with Rule 40 of the Revised Rules of Court?

RULING

Yes, the Supreme Court denied Bakun’s petition. The Court held that Sugpon’s appeal substantially complied with the requirements. First, the Notice of Appeal filed conformed with Rule 40 on its face. Second, it was reasonable for Sugpon to serve the Notice on the Sangguniang Panlalawigan of Benguet, whose members constituted the now-defunct Joint Sanggunian, as serving the defunct body was impossible. Third, Bakun’s right to due process was not impaired as it received a copy of the Notice and was able to file a motion to dismiss. Fourth, the signatories to the Notice, which included Sugpon’s board members and Mayor, did not render it defective. Finally, the non-payment of docket fees with the Joint Sanggunian was not fatal, especially since the body was dissolved, and Sugpon eventually paid the fees with the RTC Clerk of Court. The rules of procedure are tools to facilitate justice, not to frustrate it. The Court found no reversible error in the Court of Appeals’ decision.