Facts:

In the case of Crisanto M. Aala, Robert N. Balat, Datu Belardo M. Bungad, Cesar B. Cuntapay, Laura S. Domingo, Gloria M. Gazmen-Tan, and Jocelyn P. Saludares-Cadayona (Petitioners) vs. Hon. Rey T. Uy (City Mayor of Tagum City), Mr. Alfredo H. Silawan (City Assessor of Tagum City), and various City Councilors of Tagum City (Respondents), the dispute arose regarding the enactment of City Ordinance No. 558, S-2012 by the Sangguniang Panlungsod of Tagum City on March 19, 2012. Prior to this, a public hearing was held on July 12, 2011, for a proposed ordinance that aimed to adopt a new schedule of market values for real properties. City Ordinance No. 516, S-2011 was first approved on November 3, 2011, and reviewed by the Sangguniang Panlalawigan of Davao del Norte, which eventually directed amendments leading to the passage of City Ordinance No. 558, S-2012.

Petitioners objected to the ordinance on April 30, 2012, citing violations of specific provisions of the Local Government Code

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Facts:

Background and Legislative Process

• On July 12, 2011, the Sangguniang Panlungsod of Tagum City’s Committee on Finance held a public hearing to deliberate on a proposed ordinance intended to adopt a new schedule of market values and assessment levels for real properties in Tagum City.
• Subsequently, on November 3, 2011, the Sangguniang Panlungsod of Tagum City passed City Ordinance No. 516, s-2011, titled “An Ordinance Approving the New Schedule of Market Values, its Classification, and Assessment Level of Real Properties in the City of Tagum.”
• The ordinance was approved by Mayor Rey T. Uy on November 11, 2011, and then forwarded to the Sangguniang Panlalawigan of Davao del Norte for review.
• On February 7, 2012, the Committee on Ways and Means/Games and Amusement of the Sangguniang Panlalawigan of Davao del Norte declared the ordinance valid in a report, but recommended that the Sangguniang Panlungsod revise the ordinance based on recommendations from the Provincial Assessor’s Office.
• As a result, after amendments, the Sangguniang Panlungsod enacted City Ordinance No. 558, s-2012 on March 19, 2012, which was approved by Mayor Uy on April 10, 2012, and transmitted to the Sangguniang Panlalawigan on April 12, 2012.

Administrative Opposition and Procedural Developments

• On April 30, 2012, Engineer Crisanto M. Aala and Colonel Jorge P. Ferido filed an Opposition/Objection to City Ordinance No. 558, s-2012 before the Sangguniang Panlalawigan of Davao del Norte, contesting the ordinance on several grounds.
• The oppositors alleged that the ordinance violated Sections 130(a), 198(a) and (b), 199(b), and 201 of the Local Government Code of 1991 by:
• Dividing Tagum City into different zones and fixing market values based solely on location rather than actual use.
• Imposing classifications that automatically designated properties in commercial areas as commercial, irrespective of their actual use.
• They contended that such classification could lead to exorbitant real property taxes, adversely affecting residents and particularly disadvantaging poor landowners.
• Following a hearing conducted by the Committee on Ways and Means/Games and Amusement, Committee Report No. 5 was issued on May 4, 2012, which returned the ordinance to the Sangguniang Panlungsod for reconsideration and further revisions.

Reconsideration and Conflicting Actions

• On May 22, 2012, the Sangguniang Panlungsod of Tagum City issued Resolution No. 808, s-2012, requesting that the Sangguniang Panlalawigan reconsider its position regarding the ordinance.
• On June 18, 2012, the Sangguniang Panlalawigan promulgated Resolution No. 428, declaring as invalid certain sections of City Ordinance No. 558, s-2012.
• In response, on July 9, 2012, the Sangguniang Panlungsod of Tagum City passed Resolution No. 874, s-2012, affirming the validity of the ordinance. The resolution relied on Section 56(d) of the Local Government Code of 1991 and Department of Interior and Local Government Opinion No. 151, asserting that inaction within the prescribed 30-day period from submission rendered the ordinance presumptively valid.

Publication and Initiation of Litigation

• City Ordinance No. 558, s-2012 was published on July 13, 2012, in Trends and Time, a newspaper of general circulation in Tagum City, thereby signaling its impending implementation.
• Alarmed by the potential imposition of exorbitant real property taxes resulting from the ordinance’s classification scheme, petitioners composed of concerned residents and civic leaders filed an original action for Certiorari, Prohibition, and Mandamus before the Supreme Court on August 13, 2012.
• The petition sought both a temporary restraining order and a writ of preliminary injunction, arguing that the ordinance was enacted with grave abuse of discretion and that its implementation would result in substantial harm to the taxpayers of Tagum City.
• Petitioners asserted that the severity of the challenged ordinance, coupled with the inability to secure effective redress in the lower courts due to the doctrines on hierarchy of courts and exhaustion of administrative remedies, justified direct recourse to the Supreme Court.

Subsequent Pleadings and Contentions

• On October 16, 2012, respondent Geterito T. Gementiza filed a motion to be dropped from the case, citing his previous opposition to the ordinance as reason for his exclusion.
• The Court, in its ensuing resolutions and orders, required the parties to submit comments and replies concerning Gementiza’s motion and the broader substantive issues raised.
• Throughout the proceedings, petitioners argued that the ordinance amounted to a general and unlawful revision of property classification and valuation—purporting to effect a blanket categorization of all properties as commercial or industrial—which ignored the principle of actual use mandated by law.
• Respondents maintained that the ordinance allowed for a fourfold classification (agricultural, residential, commercial, and industrial), emphasizing that actual use would ultimately determine the applicable assessment, and they further contended that the procedures under Section 56(d) and other statutory provisions had been followed.

Issue:

Procedural Issues

• Whether the case falls under the exceptions to the doctrine on the hierarchy of courts, specifically whether the petitioners could directly invoke the Supreme Court’s original jurisdiction.
• Whether petitioners failed to exhaust administrative remedies as required by Section 187 of the Local Government Code of 1991 before seeking relief in the Supreme Court.
• Whether petitioners availed themselves appropriately of the extraordinary remedies of certiorari, prohibition, and mandamus given the availability of a plain, speedy, and adequate remedy in the lower courts.
• Whether respondent Geterito T. Gementiza should be dismissed from the case due to his motion requesting exclusion.

Substantive Issues

• Whether respondents committed grave abuse of discretion in preparing, enacting, and approving City Ordinance No. 558, s-2012.
• Whether the ordinance improperly classifies all real properties in Tagum City solely into commercial or industrial categories, thereby disregarding their actual use as required by law.
• Whether the schedule of market values established under the ordinance conforms to the principle that real properties must be valued based on actual use or whether it results in exorbitant assessments.
• Whether the ordinance violates constitutional guarantees such as the equal protection clause, the due process clause, and the rule on uniformity in taxation.

Ruling:

• (Subscriber-Only)

Ratio:

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Doctrine:

• (Subscriber-Only)