G.R. No. 119172 - Figuerres vs. Court of Appeals

Petitioner: Belen C. Figuerres, owner of a parcel of land (TCT No. 413305) in Barangay Mauway, Mandaluyong.
Respondents:

Officials of the then Municipality (now City) of Mandaluyong, including the Assessor, Treasurer, and the Sangguniang Bayan.
The Court of Appeals, which issued the earlier decision dismissing the prohibition suit.

The property is a residential parcel located at Amarillo Street, Barangay Mauway.
In 1993, petitioner received a notice of assessment, which provided:

Total area: 530 sq.m.
Base value: P2,500.00 per sq.m.
Computed market value and assessed value levels based on the then-applicable ordinances.

Promulgated on April 22, 1993, it contains the schedule of fair market values of various classes of real property in Mandaluyong.

Promulgated on November 11, 1993, it sets the assessment levels applicable to the real property classes.

Promulgated on February 24, 1994, it amends Ordinance No. 119 by providing that only one third (1/3) of the increase in market values for residential lands be implemented over the course of 1994, 1995, and 1996.

Enactment and enforcement of these ordinances are grounded on the Local Government Code of 1991 (R.A. No. 7160).
Department of Finance Local Assessment Regulation No. 1-92 (dated October 6, 1992) provides guidelines on the conduct of general revisions of property assessments.

The ordinances were adopted and enforced without the required public hearings or proper prior publication/posting, as mandated by law.
The ordinances allegedly failed to comply with the implementing rules and regulations to be issued by the Department of Finance.
The petitioner challenged the validity of the ordinances on the ground of non-compliance with procedural requirements.
Additionally, petitioner argued that pursuing administrative remedies would be a useless formality, contending that such exhaustion is not mandated by law under the circumstances.

Petitioner initiated a prohibition suit in the Court of Appeals aimed at preventing the enforcement of the disputed ordinances.
The Court of Appeals dismissed the petition, holding that:

There was no need for prior approval or determination by the Department of Finance since local government units are empowered under R.A. No. 7160.
The petitioner failed to exhaust the available administrative remedies as required, citing avenues such as an appeal to the Secretary of Justice or recourse to the Local Board of Assessment Appeals.
The presumption of validity of the ordinances was maintained in the absence of evidence proving non-compliance with publication, public hearing, or regulatory requirements.

Whether Ordinance Nos. 119, 125, and 135 are void due to alleged non-compliance with mandatory requirements such as public hearings and adequate publication or posting.
Whether the ordinances were improperly enacted without adhering to the Department of Finance’s guidelines.

Whether the petitioner’s failure to exhaust available administrative remedies (e.g., appeal to the Secretary of Justice, Board of Assessment Appeals) precludes judicial intervention.
Whether the rule on exhaustion of administrative remedies applies when factual issues, rather than purely legal issues, are involved.

Whether the lack of proof regarding the conduct of public hearings prior to the enactment of the ordinances undermines their constitutionality.
Whether the dissemination and publication requirements prescribed under R.A. No. 7160 were properly followed by the local government unit.