CASE DIGEST
Municipality of Bakun,
Benguet v. Municipality of Sugpon, Ilocos Sur
G.R. No. 241370, [April 20, 2022]
THIRD, LOPEZ, M.V
Boundary Dispute; LGU Territorial Jurisdiction; Law on Public Corporations; Local Government Code
Act No. 1646 in establishing the new
boundary lines between the sub-province of Amburayan and the provinces of
Ilocos Sur and La Union, and Act No. 2877 in modifying the boundaries between
the Mountain Province and the provinces of Ilocos Sur and La Union, they do not
prove that the disputed properties would form part of the territory of Bakun.
Bakun simply failed to show, by preponderant evidence, that the conflicted
areas are located within the "new boundary line."
The dispute revolves around a
1,117.20-hectare parcel of land situated within the boundaries of Bakun,
Benguet, represented by Mayor Fausto T. Labinio, and Sugpon, Ilocos Sur,
represented by Mayor Gernando C. Quiton, Sr. After failed attempts to settle the
matter, the Sangguniang Panlalawigan issued Joint Resolution No. 1, Series of
2014, adjudicating the disputed area to Bakun. Dissatisfied, Sugpon appealed to
the RTC, resulting in a Resolution on April 28, 2015, which reversed the
Sangguniang Panlalawigan's decision. The RTC argued that the laws cited by
Bakun did not delineate the boundaries, and Sugpon's evidence, particularly
maps, demonstrated its territorial jurisdiction. The CA upheld the RTC's
decision on February 1, 2018, emphasizing that Sugpon's evidence surpassed
Bakun's, and the old legislations were insufficient for boundary determination.
Whether Bakun or Sugpon holds
territorial jurisdiction over the 1,117.20-hectare disputed area.
Sugpon holds territorial jurisdiction
over the 1,117.20-hectare disputed area. The Supreme Court upheld the CA's
decision, denying Bakun's petition for review. The Court emphasized its limited
role as a reviewer of legal issues and affirmed the lower courts' findings,
supported by substantial evidence. Sugpon's evidence, including administrative
maps, tax declarations, and certifications from government offices,
convincingly established its territorial claim. In contrast, Bakun's reliance
on Act Nos. 1646 and 2877 was deemed inadequate, as these laws lacked
specificity regarding the disputed municipalities' boundaries. The Court ruled
that Bakun failed to prove, by preponderance of evidence, that the conflicted
areas fell within the modified boundary line set by the cited laws.
Consequently, the disputed area was adjudicated as part of Sugpon's territorial
jurisdiction.
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