G.R. No. 220824 . April 19, 2023.
MUNICIPALITY OF PATEROS, PETITIONER, VS. CITY OF TAGUIG AND CITY OF MAKATI, RESPONDENTS.

FACTS

The Municipality of Pateros filed a Petition for Review on Certiorari seeking to reverse the Court of Appeals’ dismissal of its appeal. The appeal stemmed from a Regional Trial Court (RTC) Resolution granting a Motion to Dismiss filed by respondent City of Makati. The core dispute involves a protracted territorial conflict over portions of the former Fort Bonifacio, specifically Barangays Cembo, South Cembo, West Rembo, East Rembo, Comembo, Pembo, Pitogo, and Bonifacio Global City. Pateros initiated its own action in 1993 (Civil Case No. 93-4529) seeking a judicial declaration of its boundaries and the nullification of Presidential Proclamations Nos. 2475 and 518, which placed the disputed areas under Makati’s jurisdiction. The RTC Makati dismissed Pateros’s case for lack of jurisdiction, a ruling affirmed by the CA and ultimately by the Supreme Court in G.R. No. 157714 .
Simultaneously, the City of Taguig filed a separate but related case (Civil Case No. 63896) against Makati over the same territory. Pateros sought to intervene in this case but was denied for failure to withdraw its own pending suit. The RTC ruled in favor of Taguig, a decision that was appealed. In a separate, final ruling in G.R. No. 235316 , the Supreme Court resolved the substantive territorial dispute between Taguig and Makati, upholding Taguig’s superior claim over the contested Fort Bonifacio areas.

ISSUE

The primary issue is whether the Court of Appeals correctly dismissed Pateros’s appeal from the RTC’s order granting Makati’s Motion to Dismiss, effectively foreclosing Pateros’s claim over the disputed territory.

RULING

The Supreme Court DENIED the petition and AFFIRMED the assailed CA rulings. The Court’s decision rests on the conclusive and preclusive effect of its final judgment in G.R. No. 235316 (Makati vs. Taguig). The legal logic is anchored on the doctrine of conclusiveness of judgment, also known as preclusion of issues or collateral estoppel. This doctrine holds that facts or issues actually and directly resolved in a former suit cannot again be raised in any future case between the same parties, even if the latter suit involves a different cause of action.
Here, the Supreme Court had already rendered a final and executory judgment definitively settling the territorial dispute over the Fort Bonifacio area in favor of the City of Taguig. In that ruling, the Court meticulously examined historical evidence, cadastral surveys, and official acts, concluding that Taguig presented a superior claim and that the disputed areas were never part of Makati’s jurisdiction. This final determination of the status and ownership of the territory is binding. Consequently, Pateros’s present action, which seeks to assert its own claim over the same parcel of land, is legally untenable. Allowing Pateros to re-litigate the fundamental issue of which local government unit has rightful jurisdiction over the territory would violate the principle of judicial finality and stability of judgments. The Court emphasized that the prior judgment in G.R. No. 235316 has conclusively resolved the core territorial question, thereby barring Pateros’s claim.