G.R. No. 235316 , December 01, 2021
Municipality of Makati (now City of Makati), Petitioner, vs. Municipality of Taguig (now City of Taguig), Respondent.

FACTS

This case originated from a territorial dispute between the Municipality (now City) of Taguig and the City of Makati over the areas comprising the Enlisted Men’s Barangays (EMBOs) and the entirety of Fort Andres Bonifacio (Fort Bonifacio). On November 22, 1993, Taguig filed a Complaint before the Regional Trial Court (RTC) of Pasig against Makati and several government officials, seeking judicial confirmation of its territory and boundary limits and a declaration of unconstitutionality of certain Presidential Proclamations. Taguig averred that the disputed areas were within its territory and jurisdiction. It alleged that Presidential Proclamation Nos. 2475 (1986) and 518 (1990), which altered its boundaries, were unconstitutional for lack of a required plebiscite. Makati filed its Answer and Amended Answer, claiming jurisdiction over the disputed areas.
Taguig’s version of facts is as follows: Taguig has existed for over 400 years. In 1902, the U.S. Government established Fort William McKinley (Fort McKinley) on a portion of Hacienda Maricaban, mainly situated in Taguig. In 1908, it purchased the remaining portion. Survey Plan Psu-2031, approved in 1909, divided Fort McKinley into parcels, with Parcel 3 and Parcel 4 located in Taguig (and Pasig for part of Parcel 4). The plan did not mention Makati. In 1957, President Carlos P. Garcia issued Proclamation No. 423, establishing Fort Bonifacio on the former Fort McKinley, stating it was located in Pasig, Taguig, Parañaque, and Pasay—not Makati. Taguig’s cadastral mapping (MCadm 590-D), approved in 1983, included all of Fort Bonifacio (Parcels 3 and 4) and conformed to the maps of adjoining LGUs, which excluded the disputed areas. In 1995, President Fidel V. Ramos issued Special Patents conveying land in Fort Bonifacio, described as situated in Taguig, to government corporations.
Makati’s version is as follows: The disputed areas were part of Hacienda Maricaban, which fell under several towns, including San Pedro Macati. In 1902, Doña Dolores Vda. de Casal sold a northeastern portion of the hacienda to the U.S. Government, which included Fort McKinley and lay within San Pedro Macati’s territory. The unsold portion was registered under Original Certificate of Title (OCT) No. 291 in Doña Casal’s name in 1906; this portion was under Taguig, Pasay, and Parañaque and did not include Fort McKinley. A sketch plan by Makati’s expert witness, certified by the DENR, showed Fort McKinley lay outside and north of the property under OCT No. 291. Makati’s cadastral mapping (MCadm 571-D), approved in 1979, included the Guadalupe and San Pedro Macati Estates, which were not in Pasay’s cadastre, and initially included only 23 barangays, not the military barangays (EMBOs).

ISSUE

The core issue is which local government unit—the City of Makati or the City of Taguig—has territorial jurisdiction over the disputed areas, namely the Enlisted Men’s Barangays (EMBOs) and the entirety of Fort Andres Bonifacio (formerly Fort William McKinley).

RULING

The Supreme Court ruled in favor of the respondent, the City of Taguig. The disputed areas comprising the Enlisted Men’s Barangays (EMBOs) and the entirety of Fort Andres Bonifacio are declared to be part of the territory of the City of Taguig. The Court found that the evidence presented, particularly historical records, official surveys, and presidential proclamations, consistently indicated that Fort McKinley/Fort Bonifacio was situated within the territorial jurisdiction of Taguig (and other municipalities) but not Makati. Key evidence included Survey Plan Psu-2031 (1909), which placed Parcels 3 and 4 in Taguig; Proclamation No. 423 (1957), which stated Fort Bonifacio was in Pasig, Taguig, Parañaque, and Pasay; Taguig’s cadastral mapping MCadm 590-D, which included the fort and conformed to adjoining municipal maps; and the Special Patents issued in 1995 describing the land as situated in Taguig. The Court found Makati’s evidence, including its cadastral map which incorporated estates not originally within its old cadastre, insufficient to overcome Taguig’s evidence. The Court also upheld the constitutionality of Presidential Proclamation No. 423, s. 1957.