GR 269159; (November, 2024) (Digest)
G.R. No. 269159, November 04, 2024
THE CITY OF CALOOCAN, REPRESENTED BY ITS CITY MAYOR, DALE GONZALO R. MALAPITAN, PETITIONER VS. THE CITY OF MALABON, ET AL., RESPONDENTS.
FACTS
Republic Act No. 9019, enacted on March 5, 2001, converted the Municipality of Malabon into a highly urbanized city. Its Section 2 defined Malabon’s boundaries, describing a southeastern boundary with the City of Caloocan. A plebiscite was conducted on April 21, 2001, ratifying the conversion. Henry P. Cammayo, former councilor of Caloocan, along with former barangay officials of Barangays 160 and 161 in Libis, Baesa, Caloocan City, filed a Petition for declaratory relief against the City of Malabon and its officials. They alleged that Section 2 of RA 9019 included portions of their barangays within Malabon’s new boundaries, thereby substantially altering the territorial jurisdiction of Caloocan without the required plebiscite under Article X, Section 10 of the Constitution. They asserted that these barangays had historically been part of Caloocan since its creation under RA 3278, with residents voting in Caloocan elections, paying taxes to Caloocan, and having titles issued by Caloocan’s Registry of Deeds. The City of Caloocan later intervened, joining the plea to declare Section 2 of RA 9019 unconstitutional. Malabon countered that the petition was improper, that the technical description in RA 9019 prevailed, that the contested areas had always been part of Malabon, and that the plebiscite for cityhood conversion was sufficient. The Regional Trial Court (RTC) ruled in favor of Caloocan, declaring RA 9019 invalid and unconstitutional. The Court of Appeals (CA) reversed the RTC, finding no constitutional violation. The City of Caloocan elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether Section 2 of Republic Act No. 9019, defining the boundaries of the City of Malabon, is unconstitutional for allegedly altering the territory of the City of Caloocan without conducting the plebiscite required under Article X, Section 10 of the 1987 Constitution.
RULING
The Supreme Court DENIED the petition and AFFIRMED the Decision of the Court of Appeals. Section 2 of RA 9019 is NOT unconstitutional.
The Court held that RA 9019 did not effect a “transfer of territorial jurisdiction” from Caloocan to Malabon that would trigger the plebiscite requirement under Article X, Section 10 of the Constitution. The provision requires a plebiscite only when there is an alteration of boundaries, which implies a change from a previous state. The petitioners failed to present clear and convincing evidence that the areas described in RA 9019 were previously under the undisputed jurisdiction of Caloocan. The evidence presented—such as tax payments, voter registration, and title issuance—were not conclusive proof of territorial jurisdiction, as they could indicate mere exercise of political authority or could be contradicted by other evidence. The case was fundamentally a boundary dispute, not a constitutional issue on the validity of the law itself. Boundary disputes between local government units are quasi-political and administrative in nature, to be resolved using the procedures under the Local Government Code, not through a declaratory relief action challenging the constitutionality of a city charter. Since no transfer of territory was conclusively established, the plebiscite conducted for the conversion of Malabon into a city, which involved its own electorate, was sufficient and valid.