Case Digest (G.R. No. 208788)
Facts:
Quezon City Government v. Manila Seedling Bank Foundation, Inc., G.R. No. 208788; G.R. No. 228284, July 23, 2024, the Supreme Court En Banc, Hernando, J., writing for the Court.The dispute stems from a seven-hectare parcel in Diliman, Quezon City that was part of a 120-hectare tract reserved by Proclamation No. 481 (1968) and later segregated by Proclamation No. 1670 (September 19, 1977) to give the Manila Seedling Bank Foundation, Inc. (the Foundation) usufructuary rights for use in its operations and projects. The Foundation long used the site as an environmental center and plant nursery and obtained a series of locational clearances/business permits. In 2000 (amended 2003) the Quezon City Council enacted the Quezon City Zoning Ordinance (Ordinance No. SP-918; Amended SP-1369), which reclassified the Foundation’s property within a Metropolitan Commercial Zone except for a 100-sqm institutional pocket where its office sat.
Pursuant to the Zoning Ordinance the City’s CPDO issued a Certificate of Non-Conformance to the Foundation on March 20, 2008 (renewed annually through 2011). When the Foundation applied to renew the locational clearance on January 5, 2012, the CPDO refused renewal, and the Foundation failed to renew its business permit for 2012. On February 23, 2012 the Foundation filed a petition for prohibition (with injunctive relief and TRO) before Branch 96, RTC, Quezon City (SCA No. Q-12-70830). The trial court granted a TRO (Jan. 4, 2013), preliminary injunctive relief (Mar. 8, 2013), and on June 18, 2013 rendered a Decision issuing a writ of prohibition permanently enjoining the City from enforcing the zoning ordinance against the subject property and ordering the City to issue a locational clearance and business permit. The City’s motions for reconsideration and for inhibition were denied; the City filed a Rule 45 petition for review on certiorari with this Court (filed Oct. 9, 2013).
Separately, on July 3, 2012 the City Treasurer notified the Foundation that the subject property had been sold at public auction for unpaid real property taxes and gave a redemption period; on July 10, 2012 the City — through DPOS officers and police — took physical possession. The Foundation filed another petition for prohibition and injunction (SCA No. Q-12-71638) in Branch 216, RTC (filed July 12, 2012). The RTC initially denied preliminary injunction for failure to prove irreparable injury and later issued an order (Dec. 22, 2014) dismissing the petition after finding the Foundation’s Certificate of Registration had been revoked by the SEC on February 21, 2002; the Court of Appeals affirmed (June 16, 2016) and denied reconsideration (Nov. 17, 2016). The Foundation then filed a Rule 45 petition with this Court (filed Nov. 25, 2016). The SEC later (Oct. 14, 2015) set aside the prior revocation.
The consolidated matters thus present (i) a direct Rule 45 challenge by the City to the RTC’...(Subscriber-Only)
Issues:
- May the City directly invoke this Court’s certiorari jurisdiction via Rule 45 to review the RTC Decision in the First Case?
- Did the Manila Seedling Bank Foundation, Inc. have the legal capacity to sue in 2012 given its SEC revocation in 2002, and is the City estopped from raising lack of capacity?
- May the Foundation, through a petition for prohibition (treated as certiorari), validly assail the validity and constitutionality of the Quezon City Zoning Ordinance?
- Can the City validly assess realty taxes on the NHA-owned subject property and sell/foreclose the same for unpaid taxes of the Foundation?
- Can the City, via the Zoning Ordinance, reclassify or regulate the use of the subject property so as t...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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