Municipality of Kananga vs. Madrona

ADMIN | DIGESTS | 2F
Case No. 18: Municipality of Kananga vs. Madrona

GR No. 141375, April 30, 2003
TOPIC: Settlement of Boundary Disputes
DOCTRINE: RTCs have general jurisdiction to adjudicate all controversies except those
expressly withheld from their plenary powers. They have the power not only to take judicial
cognizance of a case instituted for judicial action for the first time, but also to do so to the
exclusion of all other courts at that stage. Indeed, the is not only original, but also
exclusive.power
FACTS:
● A boundary dispute arose between the Municipality of Kananga and the City of Ormoc.
By agreement, the parties submitted the issue to amicable settlement by a joint session
of the Sangguniang Panlungsod of Ormoc City and the Sangguniang Bayan of
Kananga on October 31, 1997.
● No amicable settlement was reached. Instead, the members of the joint session issued
Resolution No. 97-01, which in part reads:
"x x x IT IS HEREBY RESOLVED x x x to pass a resolution certifying that both the

Sangguniang Panlungsod of Ormoc City and the Sangguniang Bayan of Kananga,
Leyte have failed to settle amicably their boundary dispute and have agreed to elevate
the same to the proper court for settlement by any of the interested party (sic)."
● To settle the boundary dispute, the City of Ormoc filed before the RTC of Ormoc City
(Branch 35) on September 2, 1999, a Complaint docketed as Civil Case No. 3722-O.
● On September 24, 1999, petitioner filed a Motion to Dismiss on the following grounds:
"(1) That the Honorable Court has no jurisdiction over the subject matter of the claim;
"(2) That there is no cause of action; and
"(3) That a condition precedent for filing the complaint has not been complied with
RTC RULING: In denying the Municipality of Kananga’s Motion to Dismiss, the RTC held that
it had jurisdiction over the action under Batas Pambansa Blg. 129. It further ruled that Section
118 of the Local Government Code had been substantially complied with, because both parties
already had the occasion to meet and thresh out their differences. In fact, both agreed to
elevate the matter to the trial court via Resolution No. 97-01. It also held that Section 118
governed venue; hence, the parties could waive and agree upon it under Section 4(b) of Rule
4 of the Rules of Court.
Not satisfied with the denial of its Motion, the Municipality of Kananga filed this Petition.
ISSUE:
● Whether or not respondent court may exercise original jurisdiction over the settlement
of a boundary dispute between a municipality and an independent component city.
ARGUMENTS
PETITIONER (NAME): RESPONDENT (NAME):
SC RULING:
The Petition has no merit.
● Under this provision, the settlement of a boundary dispute between a component city
or a municipality on the one hand and a highly urbanized city on the other -- or between
two or more highly urbanized cities -- shall be jointly referred for settlement to the
respective sanggunians of the local government units involved.
● There is no question that Kananga is a municipality constituted under Republic Act No.
542. By virtue of Section 442(d) of the LGC, it continued to exist and operate as such.
● However, Ormoc is not a highly urbanized, but an independent component, city created
under Republic Act No. 179. Section 89 thereof reads:
"Sec. 89. Election of provincial governor and members of the Provincial Board of the
Province of Leyte. – The qualified voters of Ormoc City shall not be qualified and entitled
to vote in the election of the provincial governor and the members of the provincial board
of the Province of Leyte."
● Under Section 451 of the LGC, a city may be either component or highly urbanized.
Ormoc is deemed an independent component city, because its charter prohibits its
voters from voting for provincial elective officials. It is a city independent of the province.
In fact, it is considered a component, not a highly urbanized, city of Leyte in Region VIII
by both Batas Pambansa Blg. 643, which calls for a plebiscite; and the Omnibus
Election Code, which apportions representatives to the defunct Batasang Pambansa.
There is neither a declaration by the President of the Philippines nor an allegation by
the parties that it is highly urbanized. On the contrary, petitioner asserted in its Motion
to Dismiss that Ormoc was an independent chartered city.
● Section 118 of the LGC applies to a situation in which a component city or a municipality
seeks to settle a boundary dispute with a highly urbanized city, not with an independent
component city. While Kananga is a municipality, Ormoc is an independent component
city. Clearly then, the procedure referred to in Section 118 does not apply to them.
● Nevertheless, a joint session was indeed held, but no amicable settlement was reached.
A resolution to that effect was issued, and the sanggunians of both local government
units mutually agreed to bring the dispute to the RTC for adjudication. The question
now is: Does the regional trial court have jurisdiction over the subject matter of the
claim? We rule in the affirmative.
● As previously stated, "jurisdiction is vested by law and cannot be conferred or waived
by the parties." It must exist as a matter of law and cannot be conferred by the consent
of the parties or by estoppel. It should not be confused with venue.
● Inasmuch as Section 118 of the LGC finds no application to the instant case, the general
rules governing jurisdiction should then be used. The applicable provision is found in
Batas Pambansa Blg. 129, otherwise known as the Judiciary Reorganization Act of
1980, as amended by Republic Act No. 7691. Section 19(6) of this law provides:
● "Sec. 19. Jurisdiction in civil cases. – Regional Trial Courts shall exercise exclusive
original jurisdiction:
xxx xxx xxx
"(6) In all cases not within the exclusive jurisdiction of any court, tribunal, person or body
exercising judicial or quasi-judicial functions[."
● Since there is no law providing for the exclusive jurisdiction of any court or agency over
the settlement of boundary disputes between a municipality and an independent
component city of the same province, respondent court committed no grave abuse of
discretion in denying the Motion to Dismiss. RTCs have general jurisdiction to
adjudicate all controversies except those expressly withheld from their plenary
powers. They have the power not only to take judicial cognizance of a case instituted
for judicial action for the first time, but also to do so to the exclusion of all other courts
at that stage. Indeed, the power is not only original, but also exclusive.
● In Mariano Jr. v. Commission on Elections, we held that boundary disputes should be
resolved with fairness and certainty. We ruled as follows:
● "The importance of drawing with precise strokes the territorial boundaries of a local unit
of government cannot be overemphasized. The boundaries must be clear for they
define the limits of the territorial jurisdiction of a local government unit. It can legitimately
exercise powers of government only within the limits of its territorial jurisdiction. Beyond
these limits, its acts are ultra vires. Needless to state, any uncertainty in the boundaries
of local government units will sow costly conflicts in the exercise of governmental
powers which ultimately will prejudice the people’s welfare. x x x."
● Indeed, unresolved boundary disputes have sown costly conflicts in the exercise of
governmental powers and prejudiced the people’s welfare. Precisely because of these
disputes, the Philippine National Oil Company has withheld the share in the proceeds
from the development and the utilization of natural wealth, as provided for in Section
289 of the LGC.
● WHEREFORE, the Petition is DENIED and the challenged Order AFFIRMED. No
pronouncement as to costs.
● SO ORDERED.
ADDITIONAL NOTES (DOCTRINES)

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ADMIN | DIGESTS | 2F

Case No. 18: Municipality of Kananga vs. Madrona

TOPIC: Settlement of Boundary Disputes

"x x x IT IS HEREBY RESOLVED x x x to pass a resolution certifying that both the

PETITIONER (NAME): RESPONDENT (NAME):

ADDITIONAL NOTES (DOCTRINES)

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