G.R. No. 241370 . April 20, 2022.
Municipality of Bakun, Benguet, herein represented by Mayor Fausto T. Labinio, Petitioner, vs. Municipality of Sugpon, Ilocos Sur, herein represented by Mayor Fernando C. Quiton, Sr., Respondent.

FACTS

A dispute involved a 1,117.20-hectare parcel of land within the boundaries of the Municipality of Bakun, Benguet, and the Municipality of Sugpon, Ilocos Sur. The Sangguniang Panlalawigan of Ilocos Sur and Benguet, after proceedings, issued Joint Resolution No. 1, Series of 2014, adjudicating the disputed area to Bakun. Sugpon appealed to the Regional Trial Court (RTC) of Tagudin, Ilocos Sur. The RTC reversed the Joint Resolution, adjudicating the disputed area to Sugpon, finding that the maps and other documentary evidence presented by Sugpon, which showed the area was within its territorial jurisdiction, carried greater weight. The RTC also held that Act Nos. 1646 and 2877, relied upon by Bakun, did not provide a specific delineation of the municipalities’ boundaries. The Court of Appeals affirmed the RTC’s decision, ruling that Sugpon’s evidence preponderantly established its territorial jurisdiction over the disputed property. Bakun filed a Petition for Review on Certiorari, insisting the boundary was defined by the old laws and that it presented greater weight of evidence.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s decision which adjudicated the disputed 1,117.20-hectare area to the Municipality of Sugpon, Ilocos Sur.

RULING

The petition is denied. The Supreme Court affirmed the decisions of the lower courts. The Court reiterated that it is not a trier of facts and that only questions of law are generally reviewable under Rule 45, with none of the exceptions justifying a re-evaluation of factual findings present. The Court upheld the finding that Sugpon preponderantly established its territorial jurisdiction through substantial evidence, including: Administrative and Land Classification Maps showing the area within Sugpon; certifications from the DENR and DAR; tax declarations; a certification and attestation regarding a public school under the jurisdiction of Ilocos Sur; proof of established voting centers and voter registration in Sugpon; and a Certificate of Ancestral Domain Title and petitions from residents. Conversely, Bakun’s reliance on Act Nos. 1646 and 2877 was misplaced, as these laws did not categorically fix the exact boundaries between the municipalities of Bakun and Sugpon but only described lines between the sub-province of Amburayan and the provinces of Ilocos Sur and La Union. Therefore, the disputed area is within the territorial jurisdiction of the Municipality of Sugpon, Ilocos Sur.