FACTS
The case involved the long-standing territorial boundary dispute between the City of Makati and the City of Taguig over the Fort Bonifacio Military Reservation, particularly Parcels 3 and 4 of Psu-2031, which include the Enlisted Men's Barrios (EMBO) Barangays and the Inner Fort Barangays (Barangays Post Proper Northside and Post Proper Southside). In 1993, Taguig filed before the Regional Trial Court (RTC) of Pasig a complaint for judicial confirmation of its territorial boundaries and for the declaration of the unconstitutionality of Presidential Proclamation No. 2475 (1986) and Presidential Proclamation No. 518 (1990), which allegedly transferred portions of Fort Bonifacio to Makati without the plebiscite required by the Constitution. Taguig maintained that historical records, cadastral surveys, and legislative enactments consistently showed that the disputed territory formed part of its original boundaries.
After trial, the RTC ruled in favor of Taguig, confirming that Fort Bonifacio, consisting of Parcels 3 and 4 of Psu-2031, formed part of Taguig's territorial jurisdiction. The RTC likewise declared Proclamation Nos. 2475 and 518 unconstitutional insofar as they altered local government boundaries without complying with the plebiscite requirement under Article X, Section 10 of the 1987 Constitution, and permanently enjoined Makati from exercising jurisdiction over the disputed areas. Makati filed a motion for reconsideration, a petition for annulment of judgment, and later an appeal before the Court of Appeals (CA), resulting in separate proceedings.
While Makati's appeal was pending, the Supreme Court, in a separate case, ruled that Makati had committed forum shopping by simultaneously pursuing multiple remedies involving the same RTC judgment. Taguig then moved to dismiss Makati's appeal before the CA on that ground. The CA dismissed the appeal, prompting Makati to elevate the matter to the Supreme Court. Before resolving the procedural issues, however, the Court found it necessary to settle the substantive boundary dispute because of its far-reaching consequences on territorial jurisdiction, governance, and the rights of the residents in the affected areas.
ISSUE
Whether or not Makati's appeal should be dismissed because of its willful and deliberate forum shopping arising from its simultaneous pursuit of multiple remedies involving the same judgment.
Whether or not the disputed territory comprising the EMBO Barangays and the Inner Fort Barangays forms part of the territorial jurisdiction of Makati or Taguig, based on the historical evidence, cadastral surveys, municipal charters, legislative enactments, and contemporaneous official acts.
Whether or not the Supreme Court should rule on the constitutionality of Presidential Proclamation Nos. 2475 and 518, which allegedly altered the territorial boundaries between Makati and Taguig without a plebiscite, in resolving the present controversy.
HELD
The Supreme Court DENIED Makati's petition and REINSTATED, with modification, the RTC Decision confirming that Fort Bonifacio Military Reservation, consisting of Parcels 3 and 4 of Psu-2031, is part of the territorial jurisdiction of the City of Taguig. The Court first ruled that although Makati had previously been found guilty of forum shopping, the dismissal of its appeal on that ground would not serve the broader interests of justice. Considering the significance of the territorial dispute and the public interest involved, the Court relaxed the procedural rules and proceeded to resolve the controversy on the merits. It emphasized that courts should settle genuine boundary disputes involving local government units whenever substantial justice so requires.
On the merits, the Court exhaustively examined the historical evidence, including Act No. 942 (1903), early municipal boundaries, cadastral surveys, military reservation maps, official governmental records, and contemporaneous acts of lawful authorities. It found that the overwhelming evidence consistently established that Fort McKinley (later Fort Bonifacio) historically lay within the territorial jurisdiction of Taguig, and not Makati. The Court noted that Makati's claim only appeared in later executive issuances, whereas earlier official documents, surveys, and legislative records uniformly identified the disputed territory as part of Taguig. The Court therefore concluded that Taguig presented the more convincing and credible evidence supporting its territorial claim.
The Court did not rule on the constitutionality of Presidential Proclamation Nos. 2475 and 518. Applying the doctrine of constitutional avoidance, it held that constitutional questions should be resolved only when indispensable to the disposition of the case. Since the territorial dispute could be fully resolved through historical evidence, cadastral records, and applicable laws governing municipal boundaries, there was no necessity to pass upon the validity of the proclamations. The Court likewise observed that the Office of the Solicitor General, as statutory counsel of the Republic, had not participated in the proceedings regarding the constitutional challenge, making it improper to adjudicate the issue without affording the State due process. Nevertheless, the Court clarified that the proclamations should henceforth be read consistently with its ruling that the disputed areas belong to Taguig.
Accordingly, the Supreme Court confirmed that Fort Bonifacio Military Reservation, including the EMBO Barangays and the Inner Fort Barangays, forms part of the territorial jurisdiction of the City of Taguig. It permanently recognized Taguig's superior territorial claim based on historical and legal evidence and ordered that the disputed areas be treated as belonging to Taguig for all purposes of local governance and territorial jurisdiction. The Court thus modified the RTC Decision only by refraining from declaring Presidential Proclamation Nos. 2475 and 518 unconstitutional, while fully affirming Taguig's territorial rights over the disputed area.
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