GR 141375; (April, 2003) (Digest)
G.R. No. 141375 ; April 30, 2003
MUNICIPALITY OF KANANGA, Represented by its Mayor, Hon. GIOVANNI M. NAPARI, petitioner, vs. Hon. FORTUNITO L. MADRONA, Presiding Judge, Regional Trial Court of Ormoc City (Branch 35); and the CITY OF ORMOC, Represented by its Mayor, Hon. EUFROCINO M. CODILLA SR., respondents.
FACTS
A boundary dispute arose between the Municipality of Kananga and the City of Ormoc. The parties attempted amicable settlement through a joint session of their respective Sanggunians, as encouraged by law. This effort failed, and the joint session issued a resolution certifying the failure of settlement and agreeing to elevate the dispute to the proper court. Consequently, the City of Ormoc filed a complaint before the Regional Trial Court (RTC) of Ormoc City to judicially settle the boundary dispute.
The Municipality of Kananga moved to dismiss the complaint, primarily arguing that the RTC lacked jurisdiction over the subject matter. Kananga contended that the dispute must be settled administratively under the Local Government Code, and that the RTC could not take cognizance of the case. The RTC denied the motion to dismiss, holding that it had jurisdiction under Batas Pambansa Blg. 129 and that the condition precedent for filing (amicable settlement efforts) had been substantially complied with.
ISSUE
Whether the Regional Trial Court has original jurisdiction to settle a boundary dispute between a municipality and an independent component city.
RULING
Yes, the Regional Trial Court has jurisdiction. The Supreme Court affirmed the RTC’s order denying the motion to dismiss. The governing law, Section 118 of the Local Government Code, outlines the procedure for amicable settlement of boundary disputes between specific local government units. However, it explicitly covers disputes involving a component city or municipality and a highly urbanized city, or between two highly urbanized cities. The Court found that Ormoc City is not a highly urbanized city but an independent component city, as its charter prohibits its voters from voting for provincial elective officials. The dispute between a municipality and an independent component city is not specifically provided for in Section 118.
Since no specific statutory provision governs the jurisdictional responsibility for this particular type of boundary dispute, the general rule applies. Jurisdiction is conferred by law. Under Batas Pambansa Blg. 129, as amended by Republic Act No. 7691 , Regional Trial Courts have exclusive original jurisdiction over all civil actions which cannot be filed before lower courts. A boundary dispute, being incapable of pecuniary estimation and involving the determination of territorial jurisdiction of local government units, falls within this general jurisdiction of the RTC. The Court emphasized that unresolved boundary disputes prejudice public welfare, and the judiciary must provide a forum for their settlement when the law is silent on a specific administrative pathway.