Facts:

The petitioner in this case is Eduardo N. Atienza who had filed a petition against the Court of Appeals, the Maritime Industry Authority (MARINA), and Enrico Eulogio, the private respondent. The case originated as a petition for certiorari questioning the findings of MARINA regarding Atienza's alleged misrepresentation and the subsequent denial of his motion for an extension or renewal of his provisional authority to operate a passenger vessel, M/V ACE-1. Atienza was the general manager of Manila Ace Shipping Lines, during which he registered M/V ACE-1 under his name with the First Coast Guard District in Manila. The vessel had been mortgaged to Far East Bank and Trust Company but was sold to private respondent Eulogio; the loan was settled by Eulogio following the sale. After selling the vessel, Atienza still attempted to transfer the vessel's homeport from Manila to Batangas without proper documentation, even managing to register it again under his name with the Fifth

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Facts:

Parties and Vessel Background

• Petitioner Eduardo N. Atienza, formerly the general manager of Manila Ace Shipping Lines, was involved in the operations and management of the passenger vessel M/V ACE-1.
• The vessel was initially registered in petitioner’s name with the First Coast Guard District in Manila, bearing Certificate of Ownership No. 89-0003 and Certificate of Philippine Register No. ICGD-89-00007.
• M/V ACE-1 was mortgaged to Far East Bank and Trust Company (FEBTC) and was later sold by petitioner to private respondent Enrico Eulogio, who settled the mortgage with FEBTC.

Document Transactions and Vessel Re-registration

• Upon the sale, petitioner delivered the vessel’s documents to respondent Eulogio.
• Notwithstanding the sale, petitioner initiated an attempt to transfer the vessel’s homeport from Manila to Batangas despite having already surrendered the documents.
• Petitioner managed, through undisclosed means, to register the vessel in his name with the Fifth Coast Guard District in Batangas City where he was issued a new Certificate of Ownership No. 94-0056 and Certificate of Philippine Register No. 5CGD-940059.

Requests for Re-issuance of Certificates and Subsequent Transactions

• In 1994, with certain Coast Guard functions ceded to MARINA, petitioner went to the Batangas Maritime Regional Office and claimed that the original certificates issued in Manila were “lost.”
• Relying on the newly issued documents from the Batangas Office, petitioner obtained re-issued Philippine Coast Guard certificates on December 29, 1994, which, this time, bore Manila Ace Shipping Lines as the owner rather than his personal name.
• On July 27, 1995, respondent Enrico Eulogio presented the original documents from the First Coast Guard District (which petitioner had earlier declared “lost”) to the MARINA Domestic Shipping Office.
• MARINA re-issued the certificates of ownership and vessel registry to petitioner on July 28, 1995, thus enabling a subsequent transfer of title on August 4, 1995, when the certificates were issued in the name of respondent Eulogio.

Discovery of Misrepresentation and Administrative Proceedings

• Petitioner’s misrepresentation regarding the “loss” of the original Coast Guard-issued certificates was discovered, leading to the filing of Case No. 95-120 against him.
• MARINA, issuing an order to show cause, required petitioner to explain both his misrepresentation and his failure to disclose the previous mortgage and actual sale of the vessel to respondent Eulogio.
• On February 7, 1997, petitioner was found guilty of misrepresentation and was initially imposed an administrative fine of P25,000 pursuant to Memorandum Circular No. 50-A, with subsequent reduction to P10,000 via Memorandum Circular No. 109.
• The Batangas Maritime Regional Office’s certificates (issued on December 29, 1994) were cancelled, while the certificates issued to respondent were upheld as valid and operative.

Further Motions and Procedural History

• Petitioner’s subsequent motion for extension or renewal of his provisional authority to operate the vessel, despite the cancellation of the earlier certificates, was denied on January 9, 1998.
• The petition for certiorari under Rule 65 of the Rules of Court filed by petitioner sought to annul MARINA’s decisions and resolutions; however, it was dismissed on the ground that the proper remedy was an appeal under Rule 45, not certiorari.
• The Court of Appeals (CA) decision and resolution supporting MARINA's findings were upheld on the basis that petitioner’s application for review was procedurally flawed and that appeal was the appropriate remedy.

Issue:

Procedural Appropriateness of the Remedy

• Whether petitioner’s filing of a petition for certiorari under Rule 65 was proper given that an appeal was available under Rule 45.
• Whether the petitioner’s choice of remedy constituted negligence or error leading to the loss of an available appeal.

Validity of MARINA’s Administrative Discretion

• Whether MARINA’s findings of misrepresentation and the associated imposition of an administrative fine (reduced from P25,000 to P10,000) were supportable on due process grounds.
• Whether the denial of petitioner’s motion for extension or renewal of his provisional authority to operate the vessel was a proper exercise of MARINA’s regulatory discretion.

Deference to Administrative Findings

• Whether the Court of Appeals was correct in giving great weight to MARINA’s factual determinations and technical expertise in regulating vessel registration and documentation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)