42. Barangay Mayamot, Antipolo City v. Antipolo City (Aug 17 2016 Jardeleza J.

FACTS:
 In 1984, BP 787-794 were passed creating 8 new barangays in the then Municipality of Antipolo
(Barangays Beverly Hills, Dalig, Bagong Nayon, San Juan, Sta. Cruz, Munting Dilaw, San Luis,
and Inarawan to the original eight = 16 barangays).
 The Sangguniang Bayan of Antipolo passed Resolution No. 97-80, commissioning the City
Assessor to plot and delineate the territorial boundaries of the 16 barangays.
o The Resolution also stated that the boundaries of the former 8 barangays continued to
exist.
 On September 21, 1999, Barangay Mayamot filed a Petition for Declaration of Nullity and/or
Annulment of Resolution No. 97-89 and Injunction against Antipolo City, Sangguniang
Panglungsod of Antipolo, Barangays Sta. Cruz, Bagong Nayon, Cupang, and Mambugan, the
City Assessor and the City Treasurer before the RTC of Antipolo City.
o Barangay Mayamot claimed that while BP 787-794 did not require Barangay Mayamot to
part with any of its territory, the adoption of Resolution No. 97-89 reduced its territory to
one-half of its original area and was apportioned to Barangays Sta. Cruz, Bagong Nayon,
Cupang, and Mambugan. It also claimed that the City Assessor's preparation of the plan
and the Sangguniang Panglungsod's adoption of Resolution No. 97-89 were not
preceded by any consultation nor any public hearing.
o It also alleged that Resolution 97-89 violated Sec. 82 of the Local Government
Code of 1983 which provided that alteration, modification and definition of barangay
boundaries shall be by ordinance and confirmed by a majority of the votes cast in a
plebiscite called for the purpose.
 RTC: Held that the subject Resolution did not intend to alter the territorial boundary of Petitioner.
It also held that since the case involves a boundary dispute, the LGC of 1983, the prevailing
law at the time of the passing of the subject resolution, applies.
 CA: Denied Petitioner’s appeal. Held that there is no issue in the creation of the 8 new barangays
because it was approved by the majority of the votes cast in a plebiscite held on February 5,
1986, as evidenced by Commission on Elections Resolution No. 96-2551. It also upheld the
RTC’s ruling that the subject Resolution did not alter the Petitioner’s territorial boundary.
o The CA also ruled that Secs. 118-119 of the LGC of 1991, the statute in force at the
time of commencement of Petitioner’s action, applies.
o The LGC of 1991 gives the Sagguniang Bayan the original jurisdiction to actually hear
and decide the dispute in accordance with the procedures laid down in the law and its
implementing rules and regulations. The trial court loses its power to try, at the first
instance, cases of barangay boundary disputes and only in the exercise of its appellate
jurisdiction can the RTC decide the case.
 Petitioner contends that since there was an alteration of its territory, the subject Resolutions
violated LGC of 1983. Respondents contend that since the case is a boundary dispute, the
RTC and the CA were correct in dismissing the case for lack of jurisdiction.

ISSUE: WON the LGC of 1983 applies to the case.

HELD: NO.
 Jurisdiction is defined as the power and authority of the courts to hear, try and decide cases. The
nature of an action and its subject matter, as well as which court or agency of the government
has jurisdiction over the same, are determined by the material allegations of the complaint in
relation to the law involved and the character of the reliefs prayed for, whether or not the
complainant/plaintiff is entitled to any or all of such reliefs. The designation or caption is not
controlling more than the allegations in the complaint. It is not even an indispensable part of the
complaint. Also, jurisdiction being a matter of substantive law, the established rule is that
the statute in force at the time of the commencement of the action determines the
jurisdiction of the court.
  There is a boundary dispute when a portion or the whole of the territorial area of a Local
Government Unit (LGU) is claimed by two (2) or more LGUs.
o Here, Barangay Mayamot is claiming a portion of the territory of Barangays Bagong
Nayon, Sta. Cruz, Cupang and Mambugan. Unfortunately for petitioner, the resolution of
a boundary dispute is outside the jurisdiction of the RTC.
 At the time Petitioner filed its petition before the RTC, the LGC of 1991 was already in effect. It
states that “Boundary disputes involving two (2) or more barangays in the same city or
municipality shall be referred for settlement to the sangguniang panlungsod or sangguniang
bayan concerned.”
 The CA correctly held that the RTC was correct in dismissing the petition due to lack of
jurisdiction. Indeed, whenever it appears that the court has no jurisdiction over the subject matter,
the action shall be dismissed. This defense may be interposed at any time, during appeal or even
after final judgment. Such is understandable, as this kind of jurisdiction is conferred by law and
not within the courts, let alone the parties, to themselves determine or conveniently set aside.

43. Narra Nickel Mining Development Corporation v. Redmont Consolidated Mines Corporation
(Dec 9 2015 Perlas-Bernabe J.)

FACTS:
 Redmont filed an Application for an Exploration Permit (EP) over mining areas in Rizal, Bataraza,
and Narra, Palawan.
o Redmont learned from the DENR that the said areas were already covered by an existing
Mineral Production Sharing Agreements (MPSA) and an EP, which were initially applied
for by Narra’s respective predecessors-in-interest with the Mines and Geosciences
Bureau (MGB), Region IV-B, Office of the DENR.
 Narra acquired the application of MPSA-IV-I-12 from Alpha Resources and Development
Corporation and Patricia Louise Mining and Development Corporation, and converted it into an
FTAA application.
 Petitioner Tesoro Mining and Development Inc. (Tesoro) acquired the application of MPSA-AMA-
IVB-154. Like Narra, Tesoro sought the conversion of its MPSA into an FTAA application but its
application was filed subsequent to Narra’s.
 Petitioner McArthur Mining Inc. (McArthur) acquired the application of MPSA-AMA-IVB-153, as
well as EPA-IVB-44 from Madridejos Mining Corporation. It also applied for FTAA conversion.
 All of the petitioners’ FTAA applications were approved on April 5, 2010, and seven days later the
Republic and the petitioners executed an FTAA covering the subject areas.
 Prior to the grant of the petitioners’ FTAA, Redmont filed 3 separate petitions for the denial of
petitioners' respective MPSA and/or EP applications before the Panel of Arbitrators (POA) of the
DENR-MGB.
o Redmont argued that petitioners were all controlled by their common majority
stockholder, MBMI Resources, Inc. (MBMI) - a 100% Canadian-owned corporation - and,
thus, disqualified from being grantees of MPSAs and/or EPs.
o In a decision by the SC, petitioners were declared to be foreign corporations under the
application of the "Grandfather Rule." Petitioners moved for the reconsideration of the
said Decision, which was, however, denied.
 Redmont separately sought the cancellation and/or revocation of the executed FTAA through a
Petition filed before the Office of the President (OP). They asserted that the FTAA was
anomalous and irregular because the petitioners’ mother company, MBMI, ave a long history of
violating and circumventing the Constitution and other laws, due to their questionable activities in
the Philippines and abroad.
 OP: Granted Redmont’s petition, declaring that the OP has the authority to cancel the FTAA
because the grant of exclusive power to the President of the Philippines to enter into agreements,
including FTAAs under RA 7942 (The PH Mining Act of 1995) carries with it the authority to
cancel the same.
  CA: Affirmed the OP’s ruling. It found no procedural error in the OP's action on the FTAA, holding
that it was done in accordance with the President's power of control over the executive
departments, and that it had the right to cancel the FTAA even without judicial permission.

ISSUE: WON the CA has appellate jurisdiction over the OP’s cancellation/revocation of the FTAA.

HELD: NO.
 It is a fundamental rule that the question of jurisdiction may be tackled motu proprio on
appeal even if none of the parties raised the same. The reason for the rule is that a court
without jurisdiction cannot render a valid judgment.
o The SC found that the CA had no jurisdiction over the case on appeal under Rule 43 of
the ROC since the OP’s cancellation and/or revocation of the FTAA was not one which
could be classified as an exercise of its quasi-judicial authority, thus negating the CA's
jurisdiction over the case.
o The jurisdictional parameter that the appeal be taken against a judgment, final order,
resolution or award of a "quasi-judicial agency in the exercise of its quasi-judicial
functions" is explicitly stated in Section 1 of Rule 43 (Appeals from the Court of Tax
Appeals and Quasi-Judicial Agencies to the Court of Appeals):
 This Rule shall apply to appeals from judgments or final orders of the Court of
Tax Appeals and from awards, judgments, final orders or resolutions of or
authorized by any quasi-judicial agency in the exercise of its quasi-judicial
functions.
 Quasi-judicial or administrative adjudicatory power is the power of the administrative agency
to adjudicate the rights of persons before it. The administrative body exercises its quasi-judicial
power when it performs in a judicial manner an act which is essentially executive or administrative
in nature, where the power to act in such manner is incidental to or reasonably necessary for the
performance of the executive or administrative duty entrusted to it.
o “Adjudicate” means to settle in the exercise of judicial authority or to determine finally.
o The OP's cancellation and/or revocation of the FTAA is obviously not an "adjudication" in
the sense above-described. It cannot be likened to the judicial function of a court of
justice, or even a quasi-judicial agency or office. It merely performed an administrative
function pursuant to the President’s authority.
o The cancellation of the FTAA was purely administrative in nature and cannot be
treated as adjudication.