SC upholds merger of two barangays in Calaca, Batangas

The Supreme Court (SC) has upheld the abolition of Barangay San Rafael and its merger with Barangay Dacanlao in Calaca, Batangas.

In a 28-page decision, the SC En Banc reversed and set aside a resolution of the Court of Appeals (CA) and declared void Provincial Ordinance No. 2, which repealed an earlier Sangguniang Panlalawigan Ordinance abolishing San Rafael.

“Ordinance No. 2 must be struck down for being void,” the SC said.

“It cannot repeal Ordinance No. 5, which enjoys the presumption of validity regardless of its actual implementation, and which may only be amended or repealed by another valid law,” it added.

Ordinance No. 5 was enacted by the Batangas Sangguniang Panlalawigan in 1997. It abolished San Rafael and merged with it with Dacanlao.

In 1998, a plebiscite was held where the majority supported the merger.

When the ordinance was challenged before a court, a regional trial court upheld the ordinance and confirmed the merger’s validity.

This decision was challenged before the Court of Appeals.

Meanwhile, the SC said that the Sanggunian enacted Ordinance No. 2 in 2009, which reversed the earlier merger.

It noted that this new ordinance did not include a plebiscite and lacked the required certification from the Philippine Statistics Authority to prove that San Rafael met the minimum population of 2,000 residents.

Due to the second ordinance, the CA dismissed the earlier appeal due to mootness.

The second ordinance was later challenged before an RTC, with petitioners arguing that it did not follow the legal requirements.

The RTC denied their petition while the appellate court affirmed the ruling.

In its ruling, however, the SC disagreed with the RTC and the CA.

It found that the second ordinance failed to comply with the population, a plebiscite, and the proper legislative processes.

The decision, penned by Chief Justice Alexander Gesmundo, is dated April 7, 2025. — Joahna Lei Casilao/RSJ, GMA Integrated News