G.R. No. 80796 and G.R. No. 132885; October 11, 2001
PROVINCE OF CAMARINES NORTE, et al. vs. PROVINCE OF QUEZON, et al.

FACTS

This case consolidates two petitions stemming from a final 1989 Supreme Court Decision that resolved a boundary dispute between Camarines Norte and Quezon. The 1989 Decision upheld a 1922 Executive Bureau ruling, declaring approximately 8,032 hectares comprising nine barangays as part of Camarines Norte. It ordered Quezon to cease exercising jurisdiction and directed the DENR to survey and monument the boundary. In 1991, the DENR installed a monument marker in Barangay Tabugon. Quezon Governor Eduardo Rodriguez and Calauag Mayor Julio Lim subsequently ordered the bulldozing and removal of this marker. Camarines Norte then filed a petition to cite Rodriguez and Lim in contempt for this act. Separately, in G.R. No. 132885, Quezon Province assailed COMELEC Resolutions that recognized the nine barangays as part of Camarines Norte for electoral purposes, arguing that a plebiscite was required under the Local Government Code for such a territorial transfer.

ISSUE

The core issues are: (1) Whether respondents Rodriguez and Lim are guilty of contempt for removing the boundary marker installed pursuant to a final Supreme Court Decision; and (2) Whether the COMELEC acted with grave abuse of discretion in issuing Resolutions recognizing the transfer of the barangays to Camarines Norte without a plebiscite.

RULING

The Court ruled affirmatively on both counts. On the contempt charge, the act of removing the monument constituted a willful disobedience of the Court’s 1989 final and executory judgment. The directive to monument the boundary was a specific order to physically delineate the adjudicated territory. By destroying the marker, the respondents impeded the execution of the judgment, an act punishable as indirect contempt. Their defense of protecting Quezon’s territorial claim was invalid, as the Court’s decision had already settled the issue with finality. On the second issue, the Court upheld the COMELEC Resolutions. The 1989 Supreme Court Decision was a judicial settlement of a boundary dispute, not a creation, division, or alteration of a local government unit requiring a plebiscite under the Constitution or the Local Government Code. The judicial declaration merely determined the pre-existing and correct boundary based on a 1922 administrative ruling. The COMELEC correctly implemented this judicial decree by updating electoral records to reflect the lawful jurisdiction. Therefore, Rodriguez and Lim were found guilty of contempt and fined, while the COMELEC Resolutions were affirmed as valid.