G.R. No. 162416 - De Joya vs. Marquez

On 30 June 1997, Antonio G. Principe, Regional Executive Director (RED) of DENR Region IV, issued an ECC to the National Power Corporation (NAPOCOR) authorizing the construction of a temporary mooring facility in Minolo Cove, Sitio Minolo, Barangay San Isidro, Puerto Galera, Oriental Mindoro.
The mooring facility was designed to host NAPOCOR’s 14.4-megawatt power barge—relocated from turbulent waters in Calapan—to serve as the province’s main power source pending a land‐based plant. The ECC was valid until 30 June 1999.

Petitioners, comprising local bangus fry fisherfolk, minors (represented by parents), and “the bangus, bangus fry, and other marine life” of Minolo Cove, sought DENR reconsideration of the ECC issuance on grounds of environmental threat and non‐compliance with local participation rules; RED Principe denied the motion on 15 July 1997.
On 21 July 1997, petitioners filed before the Manila RTC, Branch 7, a complaint to annul the ECC and to enjoin construction, impleading NAPOCOR, DENR officials, ORMECO, provincial and municipal officers; they secured a TRO on 28 July 1997, lifted on 6 August 1997 when construction responsibility was attributed to the provincial government. Respondents moved to dismiss on 28 August 1997 for failure to exhaust administrative remedies and lack of territorial jurisdiction. On 7 November 1997, the RTC granted the motion, dismissing the complaint for lack of cause of action and jurisdiction.

Whether the Manila RTC erred in dismissing the petitioners’ complaint for lack of jurisdiction—both subject matter and territorial—over the annulment of an ECC and issuance of injunctive relief.
Whether the complaint was properly dismissed for lack of cause of action due to petitioners’ failure to exhaust available administrative remedies, and whether any patent illegality of the ECC issuance exempted them from doing so.