Title
Laguna Lake Development Authority vs. Court of Appeals
Case
G.R. No. 120865-71
Decision Date
Dec 7, 1995
The Supreme Court affirmed that the Laguna Lake Development Authority's charter takes precedence over the Local Government Code, granting it exclusive authority to issue fishery permits and regulate activities in the Laguna Lake Region.
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Case Digest (G.R. No. 120865-71)

Facts:

  • The case involves the Laguna Lake Development Authority (LLDA) as the petitioner against the Court of Appeals, regional trial court judges, and various private entities and municipalities.
  • The LLDA was established by Republic Act No. 4850 to promote development and environmental protection in the Laguna Lake area.
  • Amendments through Presidential Decree No. 813 and Executive Order No. 927 expanded the LLDA's powers, granting it exclusive jurisdiction over permits for activities affecting Laguna de Bay.
  • The Local Government Code of 1991 (Republic Act No. 7160) was interpreted by municipalities to grant them exclusive authority to issue fishing privileges in their waters.
  • This led to an increase in unregulated fishpens and fishcages, worsening environmental issues.
  • The LLDA declared unregistered fishpens illegal and initiated demolition proceedings.
  • Fishpen owners filed injunction cases against the LLDA in regional trial courts, which denied the LLDA's motions to dismiss and issued temporary restraining orders.
  • The LLDA subsequently filed a petition for certiorari, prohibition, and injunction with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the LLDA, granting its petitions for prohibition, certiorari, and injunction.
  • The Court declared the temporary restraining orders and writs of injunction from regional trial courts null and void.
  • The LLDA was affirmed to have exclusive jurisdiction over permits for fishery privileges in the Laguna Lak...(Unlock)

Ratio:

  • The Supreme Court emphasized that the Local Government Code of 1991 did not expressly repeal the LLDA's charter, a special law.
  • The principle of statutory construction states that a general law does not repeal a special law unless there is clear intent.
  • The LLDA's charter grants it exclusive authority to regulate activities affecting Laguna de Bay, essential for environmental protection a...continue reading

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