G.R. No. 103953 - Samahang Magbubukid ng Kapdula, Inc. vs. Court of Appeals

On November 15, 1999, Israel C. Gaddi, Regional Executive Director of DENR Region XII, issued a Memorandum directing the immediate transfer of the DENR Region XII Regional Offices from Cotabato City to Koronadal (formerly Marbel), South Cotabato.
This Memorandum was pursuant to DENR Administrative Order (DAO) No. 99-14, issued by DENR Secretary Antonio H. Cerilles, which aimed at redefining functions and realigning administrative units in the regional and field offices pursuant to Executive Order No. 192 (1987) and as an interim administrative arrangement to improve DENR services.
DAO No. 99-14 established the policy of having at least one Community Environment and Natural Resources Office (CENRO) per Congressional District, except in ARMM and NCR, and authorized Regional Executive Directors to realign or relocate existing CENROs accordingly. Section 1.6 provided for the supervision of South Cotabato and Sarangani provinces to be transferred from Region XI to Region XII.

Respondents, employees of DENR Region XII and members of "COURAGE," filed a petition for nullity of orders with a preliminary injunction before the Regional Trial Court (RTC) of Cotabato, to stop the transfer of the Regional Offices.
On December 8, 1999, the RTC issued a temporary restraining order (TRO) enjoining petitioner from implementing the Memorandum transferring the offices.
Petitioner filed a Motion for Reconsideration with Motion to Dismiss, contending:

The power to transfer the Regional Office is executive in nature.
The decision to transfer was based on Executive Order No. 429, which reorganized Region XII.
The validity of E.O. 429 had been affirmed by the Supreme Court in Chiongbian v. Orbos (1995).
The courts have no jurisdiction over executive reorganization, citing Chiongbian.

On January 14, 2000, the RTC ruled to cease and desist the transfer, declaring the Memorandum void for grave abuse of discretion and lack or excess of jurisdiction, and ordered the DENR regional offices returned to Cotabato City.
The RTC denied the Motion for Reconsideration on April 10, 2000.

Petitioner filed a petition for certiorari (Rule 65) before the Court of Appeals (CA-G.R. SP No. 58896) assailing the RTC decision.
The Court of Appeals dismissed the petition outright for procedural deficiencies, including failure to:

Procedural rules should not defeat substantial justice.
Respondents have no cause of action or right to retain the regional office in Cotabato City.
State has not given consent to be sued.
The RTC decision violates the presumption of regularity in official acts.
RTC decision contradicts E.O. 429 and Republic Act No. 6734.
The transfer decision is an executive function, thus non-justiciable.

Petitioner requested liberal application of procedures given the greater interest of justice and emphasized the executive nature of the reorganization and transfer.

Whether DAO No. 99-14 and the Memorandum ordering the transfer of DENR Region XII Regional Offices were valid.
Whether the DENR Secretary has the authority to reorganize the DENR, including the authority to transfer the regional offices within the region.
Whether the judiciary has jurisdiction to interfere with the executive department’s reorganization and transfer of offices.