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49- MUNICIPALITY OF KANANGA vs. MADRONA – Pascual-Pranada

FACTS:

• A boundary dispute arose between the Municipality of Kananga and the City of 

r!oc" #y agree!ent$ the parties sub!itted the issue to a!icable settle!ent bya %oint session of theSangguniang Panlungsod of r!oc City and

the Sangguniang Bayan of Kananga on ctober &'$ '99("• )o a!icable settle!ent was reached" *nstead$ the !e!bers of the %oint session

issued +esolution )o" 9(-,'$ certifying that both the Sangguniang anlungsod of r!oc City and the Sangguniang #ayan of Kananga$ .eyte ha/e failed to settlea!icably their boundary dispute and ha/e agreed to ele/ate the sa!e to theproper court for settle!ent by any of the interested party"

•  To settle the boundary dispute$ the City of r!oc 0led before the +TC of r!oc

City 1#ranch &23 on Septe!ber $ '999$ a Co!plaint doc5eted as Ci/il Case )o"&(-"

• Municipality of Kananga$ petitioner $ 0led a Motion to 6is!iss on the followinggrounds"

1'3 That the 7onorable Court has no %urisdiction o/er the sub%ect !atter of 

the clai!813 That there is no cause of action8 and1&3 That a condition precedent for 0ling the co!plaint has not been

co!plied with"

*SS: whether respondent court !ay e;ercise original %urisdiction o/er thesettle!ent of a boundary dispute between a !unicipality and an independentco!ponent city"

7.6: of the .?C 0nds no application to the instant case$the general rules go/erning %urisdiction should then be used" The applicablepro/ision is found in # '9$ otherwise 5nown as the @udiciary +eorganiationAct of '9>,$ as a!ended by +A (B9" Section '91B3 of this law pro/ides:Sec" '9" Jurisdiction in civil cases" +egional Trial Courts shall e;ercisee;clusi/e original %urisdiction:

; ; ; ; ; ; ; ; ;1B3 *n all cases not within the e;clusi/e %urisdiction of any court$tribunal$ person or body e;ercising %udicial or =uasi-%udicial functions"

• Since there is no law pro/iding for the e;clusi/e %urisdiction of any court or

agency o/er the settle!ent of boundary disputes between a !unicipality andan independent co!ponent city of the sa!e pro/ince$ respondent courtco!!itted no gra/e abuse of discretion in denying the Motion to6is!iss" +TCs ha/e general %urisdiction to ad%udicate all contro/ersies e;cept

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those e;pressly withheld fro! their plenary powers" They ha/e the power notonly to ta5e %udicial cogniance of a case instituted for %udicial action for the0rst ti!e$ but also to do so to the e;clusion of all other courts at thatstage" *ndeed$ the power is not only original$ but also e;clusi/e"

Municipali! "#

Kanan$a%  petiti 

oner 

1'3 That the 7onorable Court has no %urisdiction o/er the

sub%ect !atter of the clai!8 - The go/erning law at the ti!e of 

the 0ling of the Co!plaint is Sec" ''> of the '99' .ocal

?o/ern!ent Code" nder this pro/ision$ the settle!ent of a

boundary dispute between a co!ponent city or a !unicipality

on the one hand and a highly urbanied city on the other -- or

between two or !ore highly urbanied cities -- shall be %ointly

referred for settle!ent to the respecti/e sanggunians of the

local go/ern!ent units in/ol/ed"

13 That there is no cause of action8 and

1&3That a condition precedent for 0ling the co!plaint has notbeen co!plied with"

CITY OF

ORMOC%

respondent 

 The +TC has %urisdiction" The go/erning law at the ti!e of 

the 0ling of the Co!plaint is Sec" ''> of the '99' .ocal

?o/ern!ent Code" Sec" ''> of the .?C applies to a situation in

which a co!ponent city or a !unicipality see5s to settle a

boundary dispute with a highly urbanied city$ not with an

independent co!ponent city" hile Kananga is a !unicipality$

r!oc is an independent co!ponent city" Clearly then$ the

procedure referred to in Section ''> does not apply to the!"&C As pre/iously stated$ %urisdiction is /ested by law and

cannot be conferred or wai/ed by the parties" *t !ust e;ist as a

!atter of law and cannot be conferred by the consent of the

parties or by estoppel" *t should not be confused with /enue"

Since there is no law pro/iding for the e;clusi/e %urisdiction of 

any court or agency o/er the settle!ent of boundary disputes

between a !unicipality and an independent co!ponent city of 

the sa!e pro/ince$ +TCs ha/e general %urisdiction to ad%udicate

all contro/ersies e;cept those e;pressly withheld fro! their

plenary powers" They ha/e the power not only to ta5e %udicial

cogniance of a case instituted for %udicial action for the 0rstti!e$ but also to do so to the e;clusion of all other courts at

that stage" *ndeed$ the power is not only original$ but also

e;clusi/e"