GR 140474; (September 2007) (Digest)
G.R. No. 140474 ; September 21, 2007
Municipality of Sta. Fe, Petitioner, vs. Municipality of Aritao, Respondent.
FACTS
Petitioner Municipality of Sta. Fe filed a case for determination of boundary dispute involving two barangays before the Regional Trial Court (RTC) in 1980. After years of trial, the RTC suspended proceedings in 1988 and referred the case to the Sangguniang Panlalawigan for possible amicable settlement, as required by the then-governing law, Batas Pambansa Blg. 337. The Sangguniang Panlalawigan, however, issued a resolution purporting to adjudicate the barangays in favor of respondent Municipality of Aritao and later endorsed the dispute back to the RTC. The RTC initially denied a motion to treat the provincial resolution as final, correctly noting the provincial board’s role was only facilitative and it could not issue a binding decision absent an amicable settlement.
ISSUE
Whether the RTC retained jurisdiction to decide the boundary dispute following the enactment of the 1987 Constitution and the Local Government Code of 1991.
RULING
No, the RTC correctly dismissed the case for lack of jurisdiction. The Supreme Court affirmed the rulings of the lower courts, holding that the controversy had been overtaken by a fundamental change in the governing law. The 1987 Constitution , in Article X, Section 10, mandates that no municipal boundary may be substantially altered except in accordance with criteria in the Local Government Code and subject to approval by a plebiscite. The Local Government Code of 1991 ( Republic Act No. 7160 ) subsequently vested the authority to settle such boundary disputes exclusively in the Sangguniang Panlalawigan concerned, subject to appeal to the proper regional trial court, and with the requirement of a plebiscite for finality. While a court that has acquired jurisdiction generally retains it, this rule yields when the change in jurisdiction is curative and reflects a new state policy. The constitutional and statutory shift to a plebiscitary requirement for boundary alterations is a substantive policy change that operates retrospectively on pending cases. Therefore, the RTC lost jurisdiction, and the dispute must be resolved through the new administrative and political process prescribed by the 1991 Code.