G.R. No. 122855 - Metro Iloilo Water District vs. Court of Appeals

Metro Iloilo Water District (MIWD) is a water district organized under Presidential Decree No. 198, as amended.
MIWD was granted the Local Water Utilities Administration Conditional Certificate of Conformance (No. 71) on January 12, 1979, covering Iloilo City and the Municipalities of Ma-asin, Cabanatuan, Santa Barbara, and Pavia.

Sometime between April and May 1993, MIWD filed nine (9) identical petitions for injunction.
The petitions sought a preliminary injunction and/or a temporary restraining order to prevent private respondents from extracting, withdrawing, and selling ground water within MIWD’s service area.
The relief sought was based on MIWD’s authority under Section 31(a) (now Section 32) of PD 198.

MIWD alleged that private respondents extracted or withdrew ground water without first securing a water permit from the National Water Resources Council (NWRC) and without registering their well drillers as required.
The unauthorized extraction and subsequent sale of water were claimed to interfere with or deteriorate the water quality and natural flows within the district.
This conduct, MIWD claimed, violated the rules promulgated by its Board of Directors governing ground water pumping and spring development, and was also asserted to be in contravention of Article XIII of PD 1067 (the Water Code).

Private respondents uniformly argued that the trial court lacked jurisdiction to hear the case, asserting that the controversy fell under the exclusive original jurisdiction of the NWRC as provided under PD 1067.
Some respondents denied any extraction or sale of ground water, while others maintained that they had complied with permit requirements or that the water extracted was from their private property or reservoirs not affecting MIWD’s operations.

The trial court, in its Order dated March 17, 1994, dismissed MIWD’s petitions on the ground that the controversy involved issues within the NWRC’s exclusive jurisdiction, particularly those relating to water appropriation and exploitation.
MIWD’s Motion for Reconsideration was denied on April 29, 1994.
A subsequent petition for review before the Supreme Court was referred to the Court of Appeals, which further affirmed the dismissal based on the jurisdictional contention that issues of water appropriation fall solely under the NWRC.

MIWD contended that the dispute was not a water rights dispute per se but an interference with its granted right to water use—the protective function inherent in its status as a water district.
MIWD emphasized that rulings in Amistoso v. Ong and Santos v. Court of Appeals supported the jurisdiction of regular courts in cases where the issue involved the enjoyment of a granted water right, not merely the appropriation of water.
Conversely, private respondents maintained that Article 88 of the Water Code gives sole original jurisdiction to the NWRC for disputes pertaining to the appropriation, utilization, exploitation, development, control, conservation, and protection of water.

Does the Regional Trial Court of Iloilo have jurisdiction to entertain MIWD’s petitions filed for an injunction against unauthorized extraction and sale of ground water?
Is the controversy properly characterized as an interference with the enjoyment of a granted water use right instead of a pure water appropriation dispute under the NWRC’s exclusive authority?

Whether the case should be determined under the regular court’s jurisdiction, which covers the enforcement of MIWD’s granted rights, or under the administrative jurisdiction of the NWRC, which deals with water appropriation and exploitation.
Whether the application of precedents such as Amistoso v. Ong and Santos v. Court of Appeals is appropriate in resolving the jurisdictional question.

Whether MIWD’s assertion of its rights under PD 198, particularly the right to prevent interference with the water within its service area, supports the exercise of judicial intervention.
Whether Article 88 of the Water Code, as invoked by the respondents, applies to this case involving an alleged infringement on the water district’s operational rights.