Case Digest (G.R. No. 186450)
Facts:
This case involves the National Water Resources Board (NWRB) as the petitioner and A.L. Ang Network, Inc. as the respondent. The events began when A.L. Ang Network, Inc. filed an application for a Certificate of Public Convenience (CPC) on January 23, 2003, to operate and maintain a water service system in Alijis, Bacolod City. The Bacolod City Water District (BACIWA) contested this application, arguing that it was the exclusive government agency permitted to operate a water service system within the city. On August 20, 2003, the NWRB granted the CPC application to A.L. Ang Network, Inc. Following this decision, BACIWA filed a motion for reconsideration, alleging a violation of due process since it had not been permitted to present evidence in opposition to the application. The NWRB reconsidered its decision and allowed BACIWA to present evidence, prompting A.L. Ang Network, Inc. to file a petition for certiorari against the NWRB and BACIWA with the Regional Trial Court (RTC) of
Case Digest (G.R. No. 186450)
Facts:
- The dispute centers on whether Regional Trial Courts (RTCs) have jurisdiction over appeals from decisions, resolutions, or orders rendered by the National Water Resources Board (NWRB).
- The petitioner is the NWRB, while the respondent is A.L. Ang Network, Inc.
Background of the Case
- On January 23, 2003, the respondent filed an application for a Certificate of Public Convenience (CPC) with the NWRB to operate and maintain a water service system in Alijis, Bacolod City.
- The Bacolod City Water District (BACIWA) opposed the application on the grounds that it is the sole government agency authorized to operate a water service system in the city.
The Application and Opposition
- The NWRB granted the CPC application on August 20, 2003.
- BACIWA moved to have the decision reconsidered, contending that its right to due process was violated since it was not allowed to present evidence in support of its opposition.
- In its reconsideration, the NWRB allowed BACIWA to present evidence.
Initial Decision and Reconsideration
- Following the reconsideration, the respondent filed a petition for certiorari with the RTC of Bacolod City against both the NWRB and BACIWA.
- The NWRB moved to dismiss the petition on the basis that the proper venue for such appeals is the Court of Appeals under Rule 43 of the Rules of Court.
Filing of the Certiorari Petition
- By Order dated April 15, 2005, the RTC dismissed the respondent’s petition for lack of jurisdiction, holding that the Court of Appeals has exclusive appellate jurisdiction over decisions of quasi-judicial agencies like the NWRB—citing the repeal of Article 89 of P.D. 1067 by BP 129.
- Subsequently, the respondent obtained a decision from the Court of Appeals on January 25, 2008, which annulled the RTC’s April 15, 2005 order and held that the RTC has jurisdiction over appeals from NWRB decisions.
Conflicting Jurisdictional Determinations
- The NWRB (petitioner) argued that the RTC lacks certiorari jurisdiction over its decisions because:
- Section 89 of P.D. 1067, which once provided for RTC jurisdiction, has been superseded and modified by BP 129 and the Rules of Court.
- There is no legal or rule-based requirement for filing petitions for certiorari against its acts in any tribunal other than the Court of Appeals.
- The respondent, on the other hand, maintained the appellate court’s interpretation that:
- Article 89 of P.D. 1067 remains a valid exception, granting the RTC jurisdiction on specific grounds such as grave abuse of discretion, questions of law, and questions of fact and law.
- Jurisprudence from cases like BF Northwest Homeowners Association and Tanjay Water District supports the RTC’s jurisdiction over certain disputes involving water-related controversies.
Arguments and Contentions of the Parties
- The decision analyses the repeal and modification of jurisdictional powers:
- BP 129, particularly Section 47, modifies and in some respects repeals certain provisions of PD 1067.
- However, the RTC had been granted jurisdiction under Article 89 of PD 1067, though this was contested based on the legislative supersession by BP 129 and the Rules of Court.
- The broader legal issue concerns the uniform application of the jurisdictional rules governing appeals from quasi-judicial agencies as provided in Rule 65 of the Rules of Court.
Legislative and Judicial Framework
Issue:
- Does the Regional Trial Court have jurisdiction over appeals from the decisions, resolutions, or orders of the National Water Resources Board?
- Is Article 89 of PD 1067, which seemingly grants such jurisdiction, still operative or has it been effectively repealed or superseded by BP 129 and the Rules of Court?
Jurisdictional Authority
- Should petitions for certiorari, particularly those invoking acts of a quasi-judicial agency like the NWRB, be filed with the Court of Appeals instead of the RTC, as mandated by the Rules of Court?
- What is the proper interpretation of the exception in Rule 65 that allows a deviation from filing with the Court of Appeals "unless otherwise provided by law or these rules"?
Proper Venue for Review
- Does the repeal or modification clause contained in BP 129 effectively remove the RTC’s appellate jurisdiction over NWRB decisions as originally conferred by PD 1067?
- How should the court resolve the conflict between the provisions of PD 1067 and the subsequent legislative enactments and rules?
Impact of Legislative Repealing Clauses
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)