SC upholds 1997 merger of San Rafael with Dacanlao in Batangas

The Supreme Court has upheld the merger of Barangay San Rafael with Barangay Dacanlao in Calaca, Batangas.

In a 28-page decision released on April 7, 2025, the SC En Banc reversed and set aside a resolution by the Court of Appeals that had dismissed an earlier appeal challenging the merger.

The dispute started in 1997 when Sangguniang Panlalawigan of Batangas abolished Bgy. San Rafael and merged it with Bgy. Dacanlao, supported by a majority vote in a plebiscite held in 1998.

In 2009, the then Sanggunian reversed the merger to restore Bgy. San Rafael without including necessary steps like a new plebiscite and population certification.

The SC declared void Provincial Ordinance No. 2 enacted in 2009 because it failed to meet legal requirements such as population certification and a plebiscite, leading the court to uphold the original merger ordinance from 1997.

Chief Justice Alexander Gesmundo penned the decision, noting that allowing Ordinance No. 2 to repeal Ordinance No. 5 would ignore the will of the people expressed in the 1998 plebiscite.

Associate Justice Alfredo Benjamin S. Caguioa dissented, arguing that the second ordinance was a valid act by Sanggunian to repeal its earlier ordinance as Bgy. San Rafael was never formally abolished.