The local city governments of Makati and Taguig of the Philippines were involved in a territorial dispute. The cities claimed jurisdiction over the entirety of the Fort Bonifacio military reservation, which includes the financial district of Bonifacio Global City (BGC) and Enlisted Men's Barrios (Embo) barangays.
Taguig has administration over Bonifacio Global City and some territory to its south as part of its Fort Bonifacio barangay. In addition, Pinagsama exercises control over the McKinley Hill area and Palar Village, while Barangay Ususan controls some exclaves along Circumferential Road 5 (C-5), such as Logcom Village, Wildcat Village, and Aranai Village. Makati claims the main Bonifacio Global City area, Bonifacio Capital District that includes McKinley Hill, Manila American Cemetery, the lands along C-5, and most parts of Palar Village and Fort Andres Bonifacio to be under the jurisdiction of its barangays, Post Proper Northside and Post Proper Southside, while Ususan's exclaves along the eastbound portion of C-5 are also claimed by Barangays Rizal and Pembo. Pateros also claims to control the Embo barangays of Makati and some barangays in Taguig and Pasig. Pateros's claim includes Bonifacio Global City. However, the legal case it filed is separate from the case involving Makati and Taguig.
In 2023, the Supreme Court ruled with finality that Taguig has jurisdiction over Fort Bonifacio and the Embo barangays. The jurisdiction of the Embo barangays were transferred to Taguig on 2023, and in September 2024, these barangays were apportioned to the two legislative districts of Taguig and Pateros. By virtue of a court order, Makati was ordered to turnover to Taguig public facilities in the Embo barangays, including health centers, covered courts, parks, multipurpose buildings, barangay halls and other government properties in May 2025.
Background
The claims of Makati and Taguig over Fort Bonifacio and the surrounding Enlisted Men's Barrios (Embo) barangays are deeply linked with historical events, land acquisitions, and legal proclamations, forming the basis of a complex territorial dispute.
Makati's claim is based on land ownership records indicating that the disputed areas and Fort William McKinley (now Fort Andres Bonifacio) were not under Taguig's jurisdiction, along with legal proclamations and various official documents such as censuses since 1918, elections since 1975, cadastral mappings, and presidential decrees. Furthermore, a directory of Rizal province, which encompassed Makati and Taguig (Tagig) at that time, showed that those areas are part of Makati as of 1934. However, those areas were not listed among Makati's (formerly San Pedro [de] Macati) barrios until the early 20th century.
On the other hand, Taguig's claim traces its existence since being a pueblo of the province of Tondo (later Manila) during the Spanish colonial rule, with legislative acts in the early 1900s enacted to revise its territory, including the annexation of the adjacent municipalities of Pateros (which also has claims on the disputed area) and Muntinlupa. It is also underscored by the establishment of Fort William McKinley within Taguig's territory, as confirmed by presidential proclamations and cadastral mappings. Key documents such as the Proclamation No. 423 of 1957 and cadastral mappings exclude the disputed areas, reinforcing Taguig's territorial claim over Fort Bonifacio.
On November 22, 1993, Taguig filed a complaint before the Regional Trial Court (RTC) of Pasig against Makati, Executive Secretary Teofisto Guingona Jr., Department of Environment and Natural Resources (DENR) Secretary Angel Alcala, and Lands Management Bureau (LMB) Director Abelardo Palad Jr. The complaint arose from Taguig's territorial dispute with Makati over the entirety of Fort Bonifacio and the Enlisted Men's Barangays (EMBOs). Taguig averred that these areas were within its territory and jurisdiction. It also alleged that Presidential Proclamation Nos. 2475, s. 1986 and 518, s. 1990 were unconstitutional because they altered Taguig's boundaries without the required plebiscite. The trial court also imposed a 20-day temporary restraining order (TRO) against Makati, Alcala, and Palad.
Supreme Court The City of Makati seeks to nullify Special Patent Nos. 3595 and 3596 signed by President Fidel V. Ramos in 1995, which places parts of Fort Bonifacio under the jurisdiction of the City of Taguig. The suit of the City of Makati was dismissed on June 27, 2008, through Associate Justice Leonardo Quisumbing. Due to a pending civil case filed by the Taguig City Government asking the court to define its territorial boundaries, the City of Makati cannot halt Taguig from collecting taxes on land located in Fort Bonifacio because it does not have any other source of sufficient income.
1994 Writ of Preliminary Injunction On August 2, 1994, the Pasig Regional Trial Court issued a Writ of Preliminary Injunction, explicitly referring to Parcels 3 and 4, Psu-2031 comprising the entirety of the Fort Bonifacio military reservation: Enjoining defendants Secretary of the Department of Environment and Natural Resources and Director of Land Management Bureau, from disposing of, executing deeds of conveyances over, issuing titles, over the lots covered by Proclamation Nos. 2475 and 518; and Enjoining defendant Makati from exercising jurisdiction over, making improvements on, or otherwise treating as part of its territory, Parcels 3 and 4, Psu-2031 comprising Fort Bonifacio. Ordering defendants to pay the cost of the suit.
2011 RTC ruling In 2011, the Pasig Regional Trial Court made permanent the 1994 Writ of Preliminary Injunction that stated the entire Fort Bonifacio Military Reservation (including the Embo barangays), consisting of Parcels 3 and 4, Psu-2031, is confirmed to be part of the territory of the City of Taguig. The ruling prevented the Department of Environment and Natural Resources (DENR) and the Land Management Bureau from disposing of, executing deeds of conveyances over, issuing titles, over the lots covered by Proclamation Nos. 2475 and 518. It also ordered the City of Makati to refrain exercising jurisdiction, making improvements on, and from treating as part of its territory the Fort Bonifacio Military Reservation.
Further rulings and appeals The City of Makati appealed the 2011 Pasig RTC ruling to the Court of Appeals. On August 5, 2013, after a year and a half of deliberations, it was decided in a 37-page decision written by Justice Marlene Gonzales-Sison of the Court of Appeals that the jurisdiction over Fort Bonifacio has reverted to Makati from Taguig. The court upheld the constitutionality of Presidential Proclamation Nos. 2475 and 518, both of which confirmed that portions of the aforementioned military camps are under the jurisdiction of Makati. The decision also cited the fact that voters from the barangays that are subject to the dispute between Makati and Taguig have long been registered as voters of Makati, thus bolstering the former's jurisdiction over Fort Bonifacio. Taguig Mayor Lani Cayetano, however, maintained that this decision was not yet final and executory, and asked Justice Gonzales-Sison to recuse herself from the case as it was discovered that her family has close ties with the Binays of Makati.
On August 22, 2013, the Taguig city government filed a motion for reconsideration before the Court of Appeals' Sixth Division, affirming its claim on Fort Bonifacio. With the filing of the motion, Taguig asserted jurisdiction over Fort Bonifacio. According to Taguig's legal department, jurisprudence, and the rules of procedure in the country's justice system, all say that the filing of a motion for reconsideration suspends the execution of a decision and puts it in limbo. On June 15, 2016, in a 27-page decision by the Second Division of the Supreme Court, the court found Makati guilty of direct contempt for forum shopping.
On October 3, 2017, the Court of Appeals upheld its final decision in favor of the city government of Taguig and not Makati. The Supreme Court also found Makati guilty of forum shopping after simultaneously appealing the Pasig Regional Trial Court (RTC) ruling and filing a petition before the Court of Appeals, both seeking the same relief. However, Makati maintained its claim over the disputed area.
Result In a decision released on April 27, 2022, the Supreme Court made permanent the 1994 Writ of Preliminary Injunction that Makati shall refrain from exercising jurisdiction over, making improvements on, or otherwise treating as part of its territory the Fort Bonifacio Military Reservation. It also upheld the 2011 Pasig RTC ruling that declared that the Bonifacio Global City, along with several surrounding barangays of Makati (Pembo, Comembo, Cembo, South Cembo, West Rembo, East Rembo, and Pitogo), was under the jurisdiction of Taguig. However, Makati released a statement saying that it would continue exercising jurisdiction over areas it controlled until it received an official copy of the decision.
On April 3, 2023, the Supreme Court junked the motion for reconsideration that was filed by Makati to override the court's earlier decision, siding with Taguig. The city government of Taguig released a statement "welcoming the new Taguigeños", referring to the residents of the affected barangays, and saying that the Taguig LGU will start working on the transition and handover of such barangays.
Makati appeal attempt Makati Mayor Abigail Binay claimed that the dispute is "not yet over", stating that her office has received a notice that the Supreme Court has set its case with Taguig for oral arguments. This was contradicted by Supreme Court spokesperson Brian Keith Hosaka, who stated that there are no such documents.
The Taguig City Government slammed Binay's comment and also expressed belief that her meeting with President Bongbong Marcos, First Lady Liza Araneta Marcos and Chief Justice Alexander Gesmundo was meant to "undermine the probity of our highest officials and subvert the people's trust in the impartiality of justice". Taguig's mayor sought sanctions against Binay for the statement.
On June 29, 2023, the SC rejected Makati's motion to file a second appeal, saying that it is generally prohibited under their rules. It also said its en banc "is not an appellate court" and will not entertain further pleadings in the case. Makati's had filed an earlier motion for reconsideration, which was rejected in 2022.
On October 5, 2023, Makati City Mayor Abigail Binay filed a motion for clarification with the petition for the issuance of a status quo ante order before the Taguig City Court Branch 153 to facilitate the proper transition of territory. This is the same court where the Taguig-Makati land row started, which was eventually resolved by the Supreme Court in favor of Taguig. The petition came after Taguig and Makati engaged in a dispute over schools and health facilities in Embo barangays, prompting national agencies to intervene.
With a decision penned on May 28, 2025, The Court of Appeals' Third Division dismissed Makati's petition to reverse Taguig RTC Branch 153's denial of its status quo ante order and urgent motion for clarification released in December 2023 and February 2024. In its decision, the Court of Appeals ruled that a writ of execution was unnecessary to enforce the final and executory ruling of the Supreme Court that favors Taguig.
Aftermath and transition