G.R. No. 170599 - Public Hearing Committee of the Laguna Lake Development Authority vs. SM Prime Holdings, Inc.

On February 4, 2002, the Pollution Control Division of the Laguna Lake Development Authority (LLDA) conducted an inspection of wastewater discharged from SM City Manila, operated by SM Prime Holdings, Inc.
Laboratory tests showed that the sampled wastewater violated effluent standards for inland water as mandated by law.
On March 12, 2002, LLDA issued a Notice of Violation to SM City Manila, ordering corrective measures to control pollution and imposing a penalty of One Thousand Pesos (₱1,000) per day from the date of inspection until the cessation of discharge.

On March 23, 2002, SM City Manila’s Pollution Control Officer requested re-sampling, claiming remedial measures were in place to meet LLDA standards.
LLDA issued an Order to Pay on October 2, 2002, requiring payment of a Fifty Thousand Pesos (₱50,000) fine, representing accumulated penalties from February 4 to March 25, 2002.
SM Prime Holdings followed up with letters dated July 2 and November 29, 2002, seeking a waiver of the imposed fines on grounds of prompt corrective action, minimal environmental damage, and assertion of being a responsible operator.
LLDA denied the waiver requests via Order dated January 10, 2003.
SM Prime submitted another letter for reconsideration on April 21, 2003.
LLDA issued a final Order to Pay on May 27, 2003, reiterating the fine and requiring payment within ten days.

Aggrieved, SM Prime filed a petition for certiorari before the Court of Appeals (CA), seeking nullification of the aforementioned LLDA Orders.
On June 28, 2004, the CA reversed and set aside the LLDA orders, ruling that LLDA did not have express authority under Republic Act No. 4850 (LLDA Charter) to impose fines, and thus acted without jurisdiction and with grave abuse of discretion.
LLDA’s Motion for Reconsideration was denied by the CA on November 23, 2005.
LLDA filed the present petition for review on certiorari before the Supreme Court, challenging the CA’s ruling on the grounds of jurisdiction, improper invocation of certiorari, and LLDA’s authority to impose fines.

Whether the CA erred in ruling that the LLDA did not have the power to impose fines for violations of effluent standards.
Whether the petition for certiorari filed by respondent with the CA was premature for failure to exhaust administrative remedies.
Whether the CA had jurisdiction to entertain the petition for certiorari filed by respondent.
Whether respondent is estopped from challenging the authority of LLDA to impose fines given its conduct during administrative proceedings.