GR 157714; (June, 2009) (Digest)
G.R. No. 157714; June 16, 2009
MUNICIPALITY OF PATEROS, Petitioner, vs. THE HONORABLE COURT OF APPEALS, THE MUNICIPALITY OF MAKATI, THE DIRECTOR OF LANDS, and THE DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES, Respondents.
FACTS
The Municipality of Pateros filed a complaint for Judicial Declaration of its Territorial Boundaries against the Municipality of Makati before the Regional Trial Court (RTC) of Makati. Pateros claimed that, based on historical records, its original area was approximately 1,038 hectares but was reduced to 166 hectares per a 1978 cadastral mapping. It attributed this reduction to Proclamation Nos. 2475 and 518, which placed the disputed areas, portions of Fort Bonifacio comprising several barangays, within Makati’s jurisdiction. Pateros sought a judicial declaration of its boundaries and the nullification of Proclamation No. 2475.
The RTC dismissed the complaint for lack of jurisdiction. It ruled that Proclamation No. 2475, a valid and subsisting law, specifically placed the subject property within Makati. Citing the Constitution and jurisprudence, it held that the substantial alteration of municipal boundaries can only be effected by an act of Congress, subject to a plebiscite, and thus the court lacked jurisdiction to fix territorial boundaries. Pateros appealed this dismissal to the Court of Appeals.
ISSUE
Whether the Court of Appeals correctly dismissed Pateros’s appeal for being a wrong mode of appeal.
RULING
Yes, the Court of Appeals correctly dismissed the appeal. The Supreme Court affirmed that the RTC’s dismissal was based purely on a question of law—specifically, the court’s lack of jurisdiction to hear a boundary dispute between local government units in light of constitutional and statutory provisions. The RTC made no factual determinations; it merely applied legal principles to conclude it could not adjudicate the case. When a trial court’s order of dismissal is grounded solely on a question of law, the proper remedy is a petition for review on certiorari directly filed with the Supreme Court, not an ordinary appeal to the Court of Appeals, pursuant to Section 2, Rule 41 of the Rules of Court. Consequently, Pateros undertook the wrong mode of appeal. The Court of Appeals, therefore, did not commit grave abuse of discretion in dismissing the appeal for lack of appellate jurisdiction. The Supreme Court further clarified that boundary disputes between municipalities are primarily administrative in nature, requiring exhaustion of remedies before the proper sanggunian under the Local Government Code, with the RTC exercising only appellate jurisdiction over such matters.