Facts:

On June 30, 1997, Antonio G. Principe, the Regional Executive Director (RED) of Region IV, Department of Environment and Natural Resources (DENR), issued an Environmental Clearance Certificate (ECC) favoring the National Power Corporation (NAPOCOR). The ECC permitted NAPOCOR to construct a temporary mooring facility in Minolo Cove, Sitio Minolo, Barangay San Isidro, Puerto Galera, Oriental Mindoro. Minolo Cove, classified as a mangrove area and a breeding ground for bangus fry, was designated an eco-tourist zone by the Sangguniang Bayan of Puerto Galera. This facility would serve as a docking site for a 14.4 megawatt power barge that would power the entire province pending the completion of a land-based power plant in Calapan, Oriental Mindoro, and the ECC was valid until June 30, 1999.

Claiming to be local fisherfolks, the petitioners filed for reconsideration of the ECC issuance, which was denied by RED Principe on July 15, 1997. Petitioners subsequently lodged a complaint in

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Facts:

Background of the Case

• On June 30, 1997, the Regional Executive Director Antonio G. Principe of DENR Region IV issued an Environmental Clearance Certificate (ECC) in favor of the National Power Corporation (NAPOCOR).
• The ECC authorized the construction of a temporary mooring facility in Minolo Cove, Sitio Minolo, Barangay San Isidro, Puerto Galera, Oriental Mindoro.
• Minolo Cove is an eco-sensitive area declared by the Sangguniang Bayan of Puerto Galera because of its mangrove stands and as a breeding ground for bangus fry.

Purpose and Need for the Mooring Facility

• The relocation of NAPOCOR’s power barge was necessitated by turbulent waters at its former mooring site in Calapan, Oriental Mindoro.
• The 14.4-megawatt power barge was intended to serve as the main power source for the province until a land-based power plant in Calapan was constructed.

Petitioners’ Actions and Grievances

• The petitioners, comprised mainly of local fisherfolks (and in some instances also including minor residents and representatives for marine life), sought reconsideration of the ECC due to alleged violations.
• They contended that the ECC was procured in violation of provisions in Presidential Decree No. 1605, the Local Government Code (Republic Act No. 7160), and the DENR’s own guidelines under DAO 96-37.
• Petitioners later filed a complaint with the Regional Trial Court (RTC) of Manila, Branch VII, praying for the cancellation of the ECC, the issuance of a writ of injunction to stop the construction, and the demolition of already built mooring structures.

Procedural History and Developments

• Following the filing, a 20-day temporary restraining order was issued by the trial court enjoining the construction; however, it was later lifted on August 6, 1997, after NAPOCOR’s explanation that the provincial government was undertaking the construction.
• Respondents, including ORMECO and provincial officials, moved to dismiss the complaint on grounds that petitioners had not exhausted the available administrative remedies.
• The trial court, on November 7, 1997, granted the motion to dismiss based on the failure to exhaust administrative remedies, which was further bolstered by arguments regarding lack of proper jurisdiction for an injunction over acts committed outside the Manila RTC’s territorial limit.

Legal and Administrative Framework

• The issuance of the ECC was based on prescribed procedures under:
• Presidential Decree No. 1586 and its implementing rules.
• DAO 96-37, including its provisions regarding documentation, submission requirements, and the complaint and appeal processes.
• Petitioners contested that NAPOCOR failed to submit necessary requirements like locational clearance or zoning certificate and did not hold consultations, thereby rendering the ECC patently illegal.
• However, respondents argued that such administrative requirements and procedural verifications are to be addressed in the administrative arena rather than through immediate judicial intervention.

Issue:

Jurisdiction and Cause of Action

• Whether the trial court erred in dismissing the petitioners’ complaint for lack of cause of action.
• Whether the Manila RTC had the proper jurisdiction over the subject matter given that the alleged acts (the construction of the mooring facility) occurred outside its territorial jurisdiction.

Exhaustion of Administrative Remedies

• Whether petitioners should have first exhausted the administrative remedies provided under DAO 96-37 before resorting to filing a complaint in court.
• The impact of bypassing the DENR’s administrative appeal process on the merits of the case.

Allegations Regarding the Environmental Clearance Certificate

• Whether the issuance of the ECC was patently illegal for failure to comply with provisions under Presidential Decree No. 1605 and Sections 26 and 27 of Republic Act No. 7160.
• Whether the omission of certain documentary requirements in the ECC application renders it void or simply subject to administrative correction.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)