G.R. No. 110120 - Laguna Lake Development Authority vs. Court of Appeals

On March 8, 1991, Task Force Camarin Dumpsite of Our Lady of Lourdes Parish filed a complaint with the LLDA against the 8.6-hectare open dumpsite in Tala Estate, Barangay Camarin, Caloocan City, citing health hazards to residents and risk of water pollution.
On November 15, 1991, LLDA conducted on-site investigation and leachate sampling, finding that the City Government of Caloocan operated the dumpsite without an Environmental Compliance Certificate (PD No. 1586) and without LLDA clearance (RA No. 4850 as amended by PD No. 813 and EO No. 927).

After a public hearing on December 4, 1991, LLDA issued a Cease and Desist Order on December 5, 1991, directing Caloocan City and its contractors to stop dumping; the City immediately complied.
In July 1992, settlement talks failed; Caloocan resumed dumping in August 1992. LLDA then issued an Alias Cease and Desist Order on August 14, 1992, and with PNP assistance enforced it on September 25, 1992, barring dump trucks.

On September 17, 1992, Caloocan City filed Civil Case No. C-15598 in RTC Branch 127 seeking nullification of LLDA’s order and a writ of injunction; a TRO was issued on September 25, 1992.
Judge Manuel Jn. Serapio consolidated this with a related case and on October 16, 1992 denied LLDA’s motion to dismiss and granted a preliminary injunction against enforcement of LLDA’s orders.
LLDA petitioned the Supreme Court for certiorari (G.R. No. 107542) on November 5, 1992; SC referred the case to the Court of Appeals on November 10, 1992, and issued a TRO restraining further dumping.

The Court of Appeals set hearings in November and December 1992, allowed LLDA to study technical plans, but parties failed to settle.
On January 29, 1993 (CA-G.R. SP No. 29449), the CA ruled that (a) the RTC lacked jurisdiction over LLDA’s orders—appeal lies exclusively with the CA under BP 129 §9(3)—and (b) LLDA has no authority under its enabling laws to issue a cease and desist order. The CA set aside LLDA’s orders and lifted the TRO on Caloocan City.

LLDA filed a petition for review on certiorari in the SC (G.R. No. 110120) seeking reinstatement of its orders; on July 19, 1993 the SC issued a TRO enjoining Caloocan City from dumping pending final resolution.

Does the LLDA, under Republic Act No. 4850 (as amended by PD No. 813 and EO No. 927), have the power to issue a cease and desist order enjoining the dumping of garbage in the Laguna Lake region?
Does the Regional Trial Court have jurisdiction to hear and decide an action for annulment of LLDA’s cease and desist order, or is such jurisdiction exclusively vested in the Court of Appeals under Batas Pambansa Blg. 129, §9(3)?