MANILA — The Supreme Court has upheld the merger of two barangays in Calaca, Batangas which have been the subject of a long-standing legal dispute. 

In an en banc decision promulgated on April 7, 2025, the court upheld the abolition of Barangay San Rafael and its merger with Barangay Dacanlao.

The dispute started in 1997 when the Sangguniang Panlalawigan of Batangas abolished Bgy. San Rafael and merged it with Bgy. Dacanlao, with the support of the majority of voters when a plebiscite was held in 1998.

After some residents challenged the ordinance, the Regional Trial Court upheld the merger but was also eventually challenged before the Court of Appeals.

In 2009 however, the then Sanggunian reversed the merger and restored Bgy. San Rafael.

But the Supreme Court noted that the new ordinance did not include a plebiscite and Bgy. San Rafael lacked the minimum population of 2,000 as required by the Local Government Code.

With the enactment of the second ordinance, the CA dismissed the appeal of the residents as the issue was already moot. 

The validity of the second ordinance however was challenged before the RTC on the argument that it did not follow the legal requirements for creating a new local government unit.

The RTC and the CA rejected the petition because the second ordinance did not actually create a new barangay as Bgy. San Rafael was already in existence.

The SC however disagreed with the RTC and the CA because the second ordinance violated the Constitution and the Local Government Code which require the holding of a plebiscite as well as a Philippine Statistics Authority certification showing the proposed barangay has at least 2,000 residents. 

“To allow Ordinance No. 2 to simply repeal Ordinance No. 5 by reasoning that the latter lacked the requirement of a plebiscite, would be to turn a blind eye to the existence of the February 28, 1998 plebiscite - and by extension, ignoring the will of the people, which had already been made known through such plebiscite,” the court said in the decision penned by Chief Justice Alexander Gesmundo.

Associate Justice Alfredo Benjamin S. Caguioa however dissented, arguing that the second ordinance was a valid act of the Sanggunian to repeal its earlier ordinance.

He stressed that it did not create a new barangay because Bgy. San Rafael was never formally abolished.

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