Settlement of Boundary Disputes in Local Government Units (LGUs)
The settlement of boundary disputes between local government units (LGUs) is governed by specific provisions under Republic Act No. 7160, also known as the Local Government Code of 1991. The Code outlines the procedure and authorities responsible for resolving disputes involving territorial boundaries between various LGUs (barangays, municipalities, cities, and provinces). Below is a meticulous breakdown of the relevant provisions and procedures.
1. Legal Basis:
Boundary disputes arise when two or more LGUs contest their territorial limits. The authority and process to settle these disputes are primarily found in:
- Section 118 of the Local Government Code of 1991
- Section 119 of the Local Government Code of 1991
- Relevant Implementing Rules and Regulations (IRR) of the Local Government Code
2. Key Principles:
- The LGUs involved should prioritize an amicable settlement of the dispute at the administrative level.
- The Sangguniang Bayan, Sangguniang Panlungsod, or Sangguniang Panlalawigan, depending on the nature of the dispute, have the jurisdiction to settle these disputes.
- Should the administrative process fail, the matter may be elevated to the courts for judicial resolution.
3. Hierarchy of Jurisdiction:
a. Disputes Between Barangays:
- Section 118(a) provides that disputes between or among barangays within the same city or municipality shall be referred for settlement to the Sangguniang Panlungsod or Sangguniang Bayan concerned.
- These legislative bodies must attempt to mediate and resolve the issue.
b. Disputes Between Municipalities or Component Cities within the Same Province:
- Section 118(b) specifies that disputes between municipalities or component cities within the same province shall be referred for settlement to the Sangguniang Panlalawigan of the province.
c. Disputes Between Highly Urbanized Cities, Independent Component Cities, or Provinces:
- Section 118(c) applies when the dispute involves highly urbanized cities, independent component cities, or provinces. The dispute is referred to the Sangguniang Panlalawigan of the province involved, or the Sangguniang Panlalawigan of the province where the independent component city or highly urbanized city is geographically located.
d. Disputes Between LGUs of Different Provinces:
- Section 118(d) governs disputes between municipalities or cities of different provinces. These disputes are referred for settlement to the Sanggunians of the provinces involved.
4. Procedural Process:
a. Filing of a Petition:
- A petition for settlement of boundary dispute must be filed by any of the LGUs involved, typically represented by their respective local chief executives (mayors or governors).
- The petition must clearly state the facts and arguments supporting the claim of the LGU regarding its boundary, often based on historical records, cadastral surveys, and official maps.
b. Mediation and Amicable Settlement:
- Upon the filing of a petition, the concerned Sangguniang Bayan, Sangguniang Panlungsod, or Sangguniang Panlalawigan is tasked with mediating the dispute.
- The goal is to arrive at an amicable settlement between the LGUs involved. The local legislative body may request the assistance of technical agencies, such as the Department of Environment and Natural Resources (DENR) for cadastral and land survey assistance.
c. Adjudication:
- If mediation fails, the local legislative body proceeds to adjudicate the dispute. A hearing may be conducted, wherein both LGUs present their evidence and arguments.
- The decision of the local legislative body should be based on the facts presented, particularly regarding official records, land surveys, historical boundaries, and legislative enactments affecting the boundaries.
d. Appeal:
- The decision of the Sangguniang Bayan, Sangguniang Panlungsod, or Sangguniang Panlalawigan may be appealed to the Regional Trial Court (RTC) within the region where the LGUs are located.
- The appeal must be made within the period prescribed under the Rules of Court.
5. Resolution by Courts:
If the dispute remains unresolved at the administrative level, or if any of the parties are dissatisfied with the decision of the local legislative body, the dispute may be brought before the courts for judicial determination.
- The courts will then rely on the same evidence, particularly the official records and cadastral surveys, to determine the proper boundaries.
- In most cases, the final arbiter of boundary disputes between LGUs is the Supreme Court, particularly when questions of law or jurisdiction are involved.
6. General Considerations in Boundary Disputes:
a. Evidentiary Weight of Historical and Official Documents:
- Cadastral Maps, Presidential Decrees, and legislative enactments (laws, ordinances) are crucial pieces of evidence in boundary disputes. These documents often provide the clearest demarcations of territorial limits and are accorded great weight in determining boundaries.
b. Role of the Department of Environment and Natural Resources (DENR):
- The DENR, through its Land Management Bureau (LMB), plays a significant role in providing technical assistance, including cadastral surveys, which are vital for determining the precise locations of disputed boundaries.
c. Amicable Settlement vs. Judicial Proceedings:
- The law encourages amicable settlement at the administrative level through mediation by the local legislative bodies. The rationale is to avoid prolonged legal battles that could strain relationships between neighboring LGUs and cause administrative inefficiencies.
d. Importance of Local Autonomy and Coordination:
- The principle of local autonomy allows LGUs to manage their own affairs, but disputes over boundaries can disrupt governance and local administration. Hence, the resolution process seeks to balance local autonomy with administrative efficiency and harmonious relations.
7. Cases on Boundary Disputes:
The jurisprudence on boundary disputes involves several cases where the Supreme Court has resolved issues based on the cadastral surveys, historical documents, and the Local Government Code. Courts consistently reiterate the necessity of factual evidence, such as historical boundaries and land surveys, in the adjudication of these disputes.
Example Case:
- Piedad Estate v. Municipality of Quezon: This landmark case involved a boundary dispute where the Court ruled based on official documents, land surveys, and historical records in determining the boundaries between LGUs.
8. Conclusion:
Boundary disputes are inherent in the administration of local government units due to the complex history of territorial demarcations in the Philippines. The Local Government Code of 1991 provides a clear legal framework to resolve these disputes, prioritizing amicable settlements through mediation and adjudication by local legislative bodies. However, unresolved disputes can be elevated to the judiciary for final resolution, emphasizing the importance of documentary evidence, especially cadastral maps, in determining the correct territorial boundaries.