G.R. No. 215494 - National Power Corp. vs. Abdo

Petitioner: National Power Corporation (NPC).
Respondents: A group composed of individuals identified as farmers, fishermen, laborers, workers, vendors, household owners, and businessmen in Marawi City and the Province of Lanao del Sur, purportedly “the poorest of the poor.”
Nature of the case: A class suit for damages filed by the respondents against the NPC and the National Transmission Corporation (TRANSCO), alleging that the construction and operation of seven hydro-electric power plants (HEPs) in Lake Lanao, and the construction and operation of a regulatory dam at the Agus River, have adversely affected their health, safety, livelihoods, and property.

Respondents claim that the HEPs and the regulatory dam were built and operated in bad faith and with gross negligence.
Allegations include adverse impacts on:

The health and safety of the local populace.
The viability of agricultural lands such as rice fields, farmlands, and fishponds.
The continuity of local businesses and household operations, due to repeated power interruptions and blackouts.

Payment and refund of various charges (including FCC, FOREX, ICC, FCPA, and PPA) allegedly collected without legal justification.
Issuance of a preliminary injunction to stop NPC from including the Purchased Power Adjustment (PPA) and related charges in electricity bills.

The RTC, Branch 8 of Marawi City, initially entertained the class suit, leading to:

An Order dated February 28, 2006, which granted a preliminary injunction in favor of the respondents and ordered NPC (and LASURECO in some instances) to pay and refund specified amounts.
A subsequent Order dated March 22, 2006, following which the respondents’ claims proceeded.

NPC’s Answer with Counterclaim questioned the validity of the class suit and highlighted procedural defects such as:

The failure of the respondents to pay the required docket fees.
The alleged lack of factual basis in the complaint, which was claimed to be founded solely on mere conjectures.

The RTC further issued orders denying NPC’s Motion for Reconsideration and directing enforcement of its ruling, despite procedural irregularities.

The CA 21st Division, in a Decision dated December 11, 2006 (in CA-G.R. SP No. 00981), set aside the RTC Resolution and Order on the ground that the respondents’ complaint failed to satisfy essential procedural requisites (notably, non-payment of docket fees and inadequacy as a valid class suit).
In a separate decision dated January 22, 2013 (in CA-G.R. CV No. 00840-MIN), the CA initially ruled in favor of NPC by setting aside the RTC orders for lack of jurisdiction.
Realizing the controlling effect of the CA 21st Division ruling, the appellate court abandoned its January 22, 2013 decision and remanded the case back to the RTC through a Resolution dated October 7, 2013.

The finality and immutability of the CA 21st Division’s decision were binding.
The remand to the RTC would erroneously vest jurisdiction in a forum that had originally been found lacking in jurisdiction due to procedural defects.

The key factual dispute centers on whether the RTC properly acquired jurisdiction over Civil Case No. 1918-03 despite:

The respondents’ failure to pay the prescribed docket fees.
The failure of the complaint to satisfy the requisites of a valid class suit under Rule 3, Section 12 of the Rules of Court.

Additional controversy arose regarding allegations of forum shopping by NPC, as it simultaneously pursued remedies in different courts.

Whether the CA erred in remanding the case to the RTC despite earlier determinations on jurisdiction.
Whether the RTC legally acquired jurisdiction to entertain Civil Case No. 1918-03 given that the respondents failed to pay the required docket fees.
Whether the respondents’ complaint qualifies as a valid class suit by satisfying the criteria of common interest, impracticability of joinder, and sufficient representation.
Whether the allegations of forum shopping are applicable in light of the existing final CA 21st Division decision.