Facts:

The case involves AC Enterprises, Inc. (ACEI) as the petitioner and Frabelle Properties Corporation (FPC) as the respondent. It concerns complaints regarding noise and air pollution emitted by the air conditioning units of the Feliza Building, owned by ACEI, situated in Makati City. The Feliza Building, a ten-story structure, contains 36 blowers from air conditioning units, with four blowers on each of its floors from the second to the tenth. These blowers were designed to direct exhaust towards the rear of Frabelle I Condominium, developed by FPC. The residential condominium is located on Rada Street, which lies parallel to Herrera Street where the Feliza Building is located.

The noise and hot air emitted by the blowers led to multiple complaints from FPC to ACEI starting in 1995. Notably, a letter dated April 11, 1995, demanded ACEI to abate the "unbearable noise" and heat emanating from the blowers. Subsequent tests conducted by the NCR Environmental Management Bur

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Facts:

Parties and Properties

• Petitioner: AC Enterprises, Inc. (ACEI)
• A duly organized corporation doing business in the Philippines.
• Owner of the 10-storey Feliza Building located along Herrera Street, Legaspi Village, Makati City.
• The building is subdivided into commercial/office units leased to private entities.
• Respondent: Frabelle Properties Corporation (FPC)
• Formerly known as FTL & Sons Development Corporation.
• Developer of Frabella I Condominium, a 29-storey commercial/residential building at 109 Rada Street, Legaspi Village, Makati City.
• Owner of some condominium units, which it leases to tenants; the building is managed by Frabella I Condominium Corporation (FCC).

Physical Relationship and Nuisance Allegations

• Spatial Orientation and Location
• Feliza Building is located behind Frabella I and separated by Rodriguez Street, a two-lane road about 12 meters wide.
• Rada and Herrera streets run parallel; Frabella I faces Feliza Building.
• Nature of the Alleged Nuisance
• The Feliza Building is equipped with 36 blowers (arranged as 4 per floor from the 2nd to the 10th floor) serving its air-conditioning system.
• These blowers are covered aesthetically by vertical concrete baffles and direct their exhaust (noise, hot air, vibration) towards Frabella I.
• It is alleged that the operation of these blowers creates a continuous, deafening, unbearable noise and blasts of hot air that interfere with the peaceful enjoyment of Frabella I tenants.

Communications, Tests, and Administrative Interventions

• Demand Letters and Correspondence
• Initial demand by respondent on April 11, 1995, to abate the nuisance.
• Petitioner’s rejection of the demand (evidenced by its letter dated May 15, 1995).
• Subsequent reiteration of demand by respondent on June 6, 1995 and again on August 14, 2000.
• Environmental Management Bureau (EMB) Testing
• Tests conducted on various dates (April–August 1995, December 1995, July 1996, November 2000, February 2003) consistently recorded noise levels exceeding the allowable limits under Section 78(b) of P.D. No. 984.
• One test (May 24, 2002) noted contributions from other sources (e.g., passing vehicles and blowers from nearby buildings) affecting ambient noise; however, the primary focus remained on the Feliza Building’s air-conditioning system.
• Involvement of Local Government and Administrative Agencies
• Respondent sought intervention from government agencies including the Makati City Health Office, City Building Official, and City Mayor.
• A panel from the EMB and the subsequent reports (including a July 19, 2002 letter from Engr. Morales, the City Building Official) played key roles in the administrative investigation.
• Despite repeated demands and testing, petitioner failed to take remedial or rectification measures.

Initiation of Legal Action

• Filing of Complaints
• On March 11, 2001, a complaint for abatement of noise/air pollution with damages was lodged before the Pollution Adjudication Board (PAB) by Frabella I Condominium Corporation.
• On July 1, 2003, respondent filed a separate complaint before the Regional Trial Court (RTC) of Malabon City for the abatement of nuisance and damages, attaching numerous letters and test reports as evidence.
• Petitioner’s Motion and Subsequent Litigation
• Petitioner moved for dismissal of respondent’s complaint on grounds including lack of jurisdiction, failure to state a cause of action, res judicata, litis pendentia, and forum shopping.
• Petitioner argued that jurisdiction belonged exclusively to the Makati City Government under R.A. No. 7160 and that similar actions (including one before the PAB) barred the current complaint.

Procedural History and Rulings

• The RTC
• Denied petitioner’s motion to dismiss in its order dated September 15, 2003.
• Held that the complaint sufficiently stated a cause of action for abatement of nuisance and damages, and that the failure to exhaust administrative remedies did not divest the court of jurisdiction.
• The Court of Appeals (CA)
• Affirmed the RTC ruling, ruling that the action for abatement of nuisance was within the court’s jurisdiction despite petitioner’s arguments regarding jurisdiction and res judicata.
• Rejected the applicability of doctrines such as primary jurisdiction and exhaustion of administrative remedies to the issues at hand.
• Petitioner’s Petition for Review on Certiorari
• Filed by petitioner challenging the CA decision, asserting that the lower courts had acted beyond their jurisdiction and abused their discretion.
• The petition was ultimately denied for lack of merit.

Issue:

Jurisdiction and the Proper Forum

• Whether the Regional Trial Court (RTC) had jurisdiction to hear an action for the abatement of a nuisance, despite claims that jurisdiction should lie exclusively with the Makati City Government under R.A. No. 7160 and DENR Administrative Order No. 30.
• Whether the actions of local government agencies (e.g., the letter issued by the City Building Official) bar the judicial determination of nuisance.

Sufficiency and Validity of the Complaint

• Whether respondent’s complaint sufficiently stated a cause of action for the abatement of a private nuisance and for damages.
• Whether allegations of continuous noise, hot air, and vibration from the Feliza Building’s blowers constitute actionable nuisance as a matter of law.

Application of Doctrines of Primary Jurisdiction and Exhaustion of Administrative Remedies

• Whether the doctrine of primary jurisdiction applies when the issues are primarily legal rather than technical.
• Whether respondent was required to exhaust administrative remedies before resorting to judicial relief—even if similar actions had been filed or pending before entities like the PAB.

Claims of Res Judicata, Litis Pendentia, and Forum Shopping

• Whether respondent’s filing of multiple complaints and the existence of prior administrative decisions (or pending cases) barred its action on grounds of res judicata, litis pendentia, or forum shopping.
• Whether the correspondence and non-adversarial findings of local government officials should preclude the court’s intervention.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Determination of Jurisdiction

• Jurisdiction is established by the nature of the dispute as illustrated in the complaint and the specific relief sought (judicial abatement of a nuisance), rather than solely by the administrative delegation of power to local government units.

• The inherent power of the courts to review and determine issues concerning nuisances, even when administrative bodies have rendered opinions or recommendations, was emphasized.

Sufficiency of Allegations

• A cause of action for nuisance exists when the defendant’s act or omission unreasonably interferes with the plaintiff’s use and enjoyment of his property.
• Repeated environmental test results and documented complaints established that the noise, hot air, and vibrations emanating from the Feliza Building’s blowers were sufficient to create a private nuisance.

Doctrinal Principles on Primary Jurisdiction and Administrative Remedies

• The doctrine of primary jurisdiction applies to technical or complex administrative issues but does not preclude judicial review where issues are fundamentally legal.
• The exhaustion of administrative remedies is not mandatory when the complaint presents a clear legal cause of action, especially when administrative actions (or inactions) do not have the force of a final adjudication.

Legal Versus Administrative Findings

• The courts clarified that administrative findings or letters by local government officials (lacking quasi-judicial proceedings) do not bind the determination of a legal nuisance claim.
• The inquiry focused on whether the alleged nuisance, given the continuous operation of the blowers and the consequent disturbance, legally constituted undue interference with property rights.

Public Policy Considerations

• The need to protect property rights and secure the peaceful and comfortable

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