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BARANGAY SANGALANG v. BARANGAY MAGUIHAN

FACTS:

The jurisdiction dispute in this case arises between Barangay Sangalang and Barangay Maguihan in Lemery, Batangas, regarding properties covered by Tax Declaration Nos. 038-00315, 038-00316, and 038-00317. The Sangguniang Bayan referred the case to a hearing committee, which concluded that the properties belonged to Barangay Sangalang. This determination was subsequently affirmed by the Sangguniang Bayan in Resolution No. 75-96.

However, the respondent disagreed with this decision and appealed to the Regional Trial Court (RTC). In its ruling, the RTC favored the respondent, declaring that the properties fell within the territorial jurisdiction of Barangay Maguihan. Unsatisfied with the ruling, the petitioner filed a motion for reconsideration, which the RTC denied.

The petitioner then resorted to filing a notice of appeal, seeking to appeal the RTC's decision. But the Court of Appeals (CA) dismissed the appeal, stating that the petitioner used the wrong remedy by filing a notice of appeal instead of a petition for review. The CA denied the petitioner's subsequent motion for reconsideration.

Consequently, the case has now reached the Supreme Court.

ISSUES:

  1. Whether the Court of Appeals (CA) should have dismissed petitioner's appeal for availing the wrong remedy.

  2. Whether the documents presented by petitioner are sufficient to prove its claim that the lots in dispute belong to Barangay Sangalang, Lemery, Batangas?

  3. Whether the documents presented by respondent carry more weight and should be given greater consideration in determining the territorial jurisdiction of the lots in dispute?

  4. Whether the respondent’s claim of ownership over the disputed property should be granted.

RULING:

  1. Yes, the CA should not have dismissed petitioner's appeal solely on the ground of availing the wrong remedy. The Court recognizes the trend towards a liberal construction of procedural rules and the duty to reconcile the need to expedite litigation with the parties' right to due process. The discretion to dismiss or not to dismiss an appellant's appeal lies with the court, and technicalities should be avoided. The court's primary duty is to render justice and litigation should be decided on their merits and not on technicality.

  2. The Supreme Court ruled that the documents presented by petitioner are not sufficient to prove its claim. The documents sourced from the tax assessor's office are not as reliable and authoritative as the documents sourced from the land management bureau. The certification from the Office of the Provincial Assessor and the tax declarations do not carry the same weight as the cadastral map approved by the Director of Lands. Therefore, the documents presented by petitioner cannot be considered as conclusive evidence of the territorial jurisdiction of the lots in dispute.

  3. The Supreme Court ruled that the documents presented by respondent, particularly the cadastral map approved by the Director of Lands, should be given more weight and considered as controlling in determining the territorial jurisdiction. The Land Management Bureau is the principal government agency tasked with the survey of lands, and its documents are presumed to have been done in the ordinary course of business. In contrast, the duties of provincial and municipal assessors are primarily assessments of taxes and not the survey of lands. Therefore, the certification of a geodetic engineer from the land management bureau carries more weight and should be considered as controlling, unless there is evidence of abuse of discretion.

  4. The petition is partly granted. The decision and resolution of the Court of Appeals are reversed and set aside. The decision and order of the Regional Trial Court affirming the respondent's ownership claim over the disputed property are affirmed.

PRINCIPLES:

  • Jurisdictional responsibility for settlement of boundary disputes between local government units is lodged before the proper Sangguniang Panlungsod or Sangguniang Bayan concerned, and a failure of amicable settlement leads to a formal trial by the sanggunian concerned (Section 118 and 118(e) of the Local Government Code).

  • Decision of the sanggunian concerned may be appealed to the RTC having jurisdiction over the area in dispute (Section 119 of the Local Government Code).

  • An ordinary appeal is the remedy for cases decided by the RTC in its original jurisdiction, while a petition for review is the remedy for cases decided by the RTC in its appellate jurisdiction (Section 2, Rule 41 of the Rules of Court).

  • Courts have the discretion to dismiss or not to dismiss an appellant's appeal and should exercise their discretion in accordance with justice and fairness. Technicalities that impede the cause of justice are to be avoided (Ong Lim Sing, Jr. v. FEB Leasing and Finance Corporation).

  • Rules of procedure should be used to secure, not override, substantial justice. Dismissal of appeals on technical grounds is frowned upon, and the court should excuse a technical lapse to afford the parties a review of the case on appeal (Aguam v. Court of Appeals).

  • In boundary disputes, the documents and procedures outlined in Article 17, Rule III of the Rules and Regulations Implementing the Local Government Code of 1991 should be followed.

  • The cadastral map approved by the Director of Lands carries more weight and should be given greater consideration in determining territorial jurisdiction.

  • Documents sourced from the land management bureau, which is the principal government agency tasked with land surveying, are more authoritative and reliable compared to documents sourced from the tax assessor's office.

  • The duty of provincial and municipal assessors is primarily the assessment of taxes and not the survey of lands.

  • Determination of the territorial jurisdiction is based on the approved barangay map and not on the decision of the populace.

  • When there is a conflict between the tax declaration and the survey plan prepared by the government agency tasked with surveying lands, the latter usually prevails, absent any proof that would cast doubt on the contents thereof.