Municipality of Sta. Fe vs. Municipality of Aritao

Original jurisdiction to hear and decide a municipal boundary dispute is vested in the Sangguniang Panlalawigan under the Local Government Code of 1991; the Regional Trial Court retains only appellate jurisdiction, and this jurisdictional reallocation applies retroactively to cases pending at the time of the law’s effectivity when the statute implies retroactive operation and no vested rights are prejudiced. Accordingly, a trial court must dismiss, for lack of jurisdiction, a boundary dispute case filed under an earlier law that conferred original jurisdiction upon it, as the absence of jurisdiction renders any judgment a nullity.

Petitioner Municipality of Sta. Fe and respondent Municipality of Aritao are neighboring local government units in the Province of Nueva Vizcaya. The two municipalities disputed territorial jurisdiction over the barangays of Bantinan and Canabuan. To obtain a definitive judicial determination of the boundary, Sta. Fe filed a complaint before the Regional Trial Court of Bayombong, Nueva Vizcaya, invoking the procedure then prescribed by Section 2167 of the Revised Administrative Code, as amended by Republic Act No. 6128, which gave the Court of First Instance original jurisdiction to hear and decide municipal boundary disputes.

• Nature: In October 1980, petitioner Municipality of Sta. Fe initiated Civil Case No. 2821 before the RTC of Bayombong, Nueva Vizcaya, for the determination of a boundary dispute with respondent Municipality of Aritoa concerning the barangays of Bantinan and Canabuan. At the time of filing, Section 2167 of the Revised Administrative Code, as amended by Republic Act No. 6128, conferred upon the Court of First Instance original jurisdiction to hear and decide municipal boundary disputes, subject to a mandatory referral to the provincial board for possible amicable settlement before trial resumed.

• Pre-Trial and Trial Proceedings: The parties failed to settle amicably during pre-trial, and trial on the merits proceeded. After petitioner had presented its rebuttal witness, the trial court, on December 9, 1988, suspended the proceedings and referred the dispute to the Sangguniang Panlalawigan of Nueva Vizcaya. The Sanggunian referred the matter to its Committee on Legal Affairs, which recommended the adoption of a prior provincial board resolution (Resolution No. 64, dated September 14, 1979) that adjudicated the disputed barangays as part of respondent’s territory. On November 13, 1989, the Sangguniang Panlalawigan issued Resolution No. 357, approving the committee’s recommendation while simultaneously endorsing the boundary dispute back to the RTC for further proceedings, maintaining the status quo pending final resolution.

• Motions and the RTC’s Dismissal: Back in the trial court, respondent moved to treat Resolution No. 64 as final and executory. The RTC denied the motion, ruling that the provincial board had exceeded its authority by issuing a decision instead of merely facilitating an amicable settlement. Subsequently, on June 23, 1992, respondent filed a motion to dismiss for lack of jurisdiction, relying on the doctrine in Municipality of Sogod v. Rosal and the newly effective Local Government Code of 1991. The RTC granted the motion on August 27, 1992, holding that the enactment of the 1987 Constitution and the Local Government Code of 1991 had “overtaken” the case: the Constitution required a plebiscite for substantial boundary alterations, and the Code vested original jurisdiction over boundary disputes in the Sangguniang Panlalawigan, leaving the trial court without authority to decide the case at first instance.

• Appeal to the Court of Appeals: Petitioner appealed to the Court of Appeals, which affirmed the dismissal. The appellate court acknowledged the general rule that jurisdiction once acquired is not lost by new legislation, but held that the change was “curative in character” and reflected the latest will of the people; thus, the 1987 Constitution and the Local Government Code of 1991 must be given retroactive effect on pending boundary dispute cases.

• Misapplication of Precedent: Petitioner argued that the RTC and the CA erroneously applied Municipality of Sogod v. Rosal. That case involved complaints filed when the old Section 2167 of the Revised Administrative Code—which gave original jurisdiction to provincial boards—was still in force. By contrast, the present suit was filed in 1980 under Republic Act No. 6128, which expressly vested original jurisdiction in the trial court. The factual settings were therefore materially different, and the Sogod doctrine should not govern.

• Prospective Application of New Laws: Petitioner maintained that the provisions of the 1987 Constitution and the Local Government Code of 1991 on the settlement of boundary disputes should be applied prospectively. The RTC had already acquired jurisdiction over the case under the law in force at the time of filing, and its jurisdiction could not be divested by a subsequent statute absent clear language to the contrary.

• Reliance on Inapplicable Provisions: Petitioner contended that the Court of Appeals erroneously relied on the general provisions of the Constitution and the Code governing the creation, division, merger, and alteration of boundaries of political units, instead of the specific provisions on the settlement of boundary disputes found in Sections 118 and 119 of the Local Government Code of 1991.

• Lack of Jurisdiction Under the New Law: Respondent asserted that at the time the motion to dismiss was filed, the Local Government Code of 1991 had already conferred original and exclusive jurisdiction over municipal boundary disputes upon the Sangguniang Panlalawigan. The RTC therefore had no authority to proceed, and the dismissal was proper under the doctrine of Municipality of Sogod v. Rosal, which recognized that changes in the law governing boundary disputes could overtake pending litigation.

• Jurisdiction: Whether the Regional Trial Court correctly dismissed Civil Case No. 2821 for lack of jurisdiction on the ground that the Local Government Code of 1991 vested original jurisdiction over municipal boundary disputes in the Sangguniang Panlalawigan, despite the case having been filed at a time when the trial court possessed such original jurisdiction.

• Retroactivity: Whether the jurisdictional provisions of the 1987 Constitution and the Local Government Code of 1991 operate retroactively to divest a trial court of jurisdiction already acquired over a pending boundary dispute case.

• Jurisdiction: The dismissal was proper. Under the Local Government Code of 1991, the Sangguniang Panlalawigan is specifically vested with original jurisdiction to hear and decide municipal boundary disputes. Sections 118 and 119 of the Code, together with the implementing rules, outline a comprehensive procedure whereby the Sanggunian first endeavors to bring about an amicable settlement, and if settlement fails, formally tries and decides the dispute. This statutory scheme reverts to the original rule under the Revised Administrative Code prior to its amendment by Republic Act No. 6128, under which provincial boards were empowered to investigate, hear, and decide such cases. In the current framework, the trial court no longer possesses the power to try a municipal boundary dispute at the first instance; its role is limited to the exercise of appellate jurisdiction upon elevation of the Sanggunian’s decision. Consequently, when the motion to dismiss was filed, the RTC’s want of jurisdiction over the subject matter was patent, and it was duty-bound to dismiss the action, as a judgment rendered without jurisdiction is a total nullity that may be struck down at any time.

• Retroactivity: The jurisdictional shift applied to the pending case. Although the general rule is that jurisdiction once acquired is not affected by new legislation transferring jurisdiction to another tribunal, an exception lies where the statute, either expressly or by necessary implication, is intended to operate on actions pending before its enactment. The 1987 Constitution and the Local Government Code of 1991 manifest an overarching policy of empowering local government units without further delay. Their new requirements regarding the constitution and boundaries of political subdivisions are, by this design, intended to apply immediately to all existing local government entities, including those embroiled in pending disputes. No substantial prejudice results from retroactive application because the RTC retains appellate authority to review the Sanggunian’s decision, thereby preserving a judicial remedy. Thus, the dismissal for lack of jurisdiction did not deprive petitioner of due process or impair any vested right.

• Jurisdiction over municipal boundary disputes under R.A. No. 7160 — Original jurisdiction to hear and decide a boundary dispute between two or more municipalities in the same province is vested in the Sangguniang Panlalawigan. The Regional Trial Court’s participation is confined to appellate review. This framework implements Section 118(b) and (e) and Section 119 of the Local Government Code of 1991, and its implementing rules (Administrative Order No. 270). The procedure requires the Sanggunian to first facilitate amicable settlement; if settlement fails within sixty days, it must issue a certification, formally try the dispute, and decide within a further sixty-day period.

• Retroactive application of curative jurisdictional statutes — A statute altering the jurisdiction of courts may be applied to pending cases if retroactive intent is either expressed or necessarily implied, and no vested right, contractual obligation, or property right is impaired without due process. A law is construed to have retroactive effect when it is “curative” or when its dominant purpose is to immediately enfranchise or empower a class of governmental units, and retroactivity occasions no substantial prejudice because an alternative judicial forum remains available.

• Effect of want of jurisdiction — The jurisdiction of a court is conferred solely by law. Dismissal for lack of jurisdiction over the subject matter may be raised at any stage of the proceedings. A decision rendered without jurisdiction is void ab initio and never becomes final and executory; it may be assailed at any time.

• “Under present laws, the function of the provincial board to fix the municipal boundaries are now strictly limited to the factual determination of the boundary lines between municipalities, to be specified by natural boundaries or by metes and bounds in accordance with laws creating said municipalities.” (RTC order quoting Municipality of Sogod v. Rosal, adopted in the Supreme Court decision)

• “An exception to this rule, however, lies where the statute either expressly provides or is construed to the effect that it is intended to operate on actions pending before its enactment.”

• “It is readily apparent from the provisions of the 1987 Constitution and the LGC of 1991 that their new provisions and requirements regarding changes in the constitution of political units are intended to apply to all existing political subsidiaries immediately, i.e., including those with pending cases filed under the previous regime, since the overarching consideration of these new provisions is the need to empower the local government units without further delay.”

• “Under the LGC of 1991, the trial court loses its power to try, at the first instance, cases of municipal boundary disputes. Only in the exercise of its appellate jurisdiction can the proper RTC decide the case, on appeal, should any party aggrieved by the decision of the Sangguniang Panlalawigan elevate the same.”

• Municipality of Sogod v. Rosal, G.R. Nos. 38204-5, September 24, 1991, 201 SCRA 632 — Applied by the trial court and the Court of Appeals; the Supreme Court held that even though the factual antecedents differed, the principle that a pending boundary dispute may be “overtaken by events” (i.e., a new law on jurisdiction) remained controlling.

• Philippine Long Distance Telephone Company v. Dulay, G.R. No. 53446, April 12, 1989, 172 SCRA 31 — Cited for the general rule that jurisdiction once acquired is not lost by new legislation, thereby setting the baseline for the recognized exception.

• Atlas Fertilizer Corporation v. Navarro, No. L-72074, April 30, 1987, 149 SCRA 432 — Cited for the exception that a statute may govern pending actions if it expressly or impliedly so provides.

• Section 118(b) and (e), Republic Act No. 7160 (Local Government Code of 1991) — Mandates that boundary disputes involving two or more municipalities within the same province be referred for settlement to the Sangguniang Panlalawigan; if amicable settlement fails within sixty days, the Sanggunian shall formally try and decide the dispute. These provisions were the basis for vesting original jurisdiction in the Sanggunian and divesting the RTC of trial jurisdiction at first instance.

• Section 119, Republic Act No. 7160 — Grants any aggrieved party the right to appeal the Sanggunian’s decision to the proper Regional Trial Court, which shall decide the appeal within one year. This provision preserved the RTC’s appellate jurisdiction and supported the conclusion that no substantial prejudice resulted from the jurisdictional shift.

• Article X, Section 10, 1987 Constitution — Requires that no province, city, municipality, or barangay be created, divided, merged, abolished, or have its boundary substantially altered except in accordance with criteria in the Local Government Code and subject to approval by plebiscite. Cited to emphasize that boundary disputes had been overtaken by a new constitutional mandate requiring direct participation of affected political units.

Chief Justice Reynato S. Puno (Chairperson), Associate Justice Angelina Sandoval-Gutierrez, Associate Justice Renato C. Corona, Associate Justice Cancio C. Garcia.