Case Digest (G.R. No. 148622) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On August 11, 2000, the City of Davao, represented by Mayor Benjamin C. de Guzman, filed an application for a Certificate of Non-Coverage (CNC) with the Environmental Management Bureau (EMB), Region XI, for its proposed Davao City Artica Sports Dome project. The submission included a detailed location map, a brief project description, and a certification from the City Planning and Development Office that the site was not in an Environmentally Critical Area (ECA). The EMB denied the request, ruling that the project fell within an ECA and, under Presidential Decree No. 1586 (PD 1586) in relation to Presidential Decree No. 1151, the City must undergo the Environmental Impact Statement (EIS) process to secure an Environmental Compliance Certificate (ECC). Believing itself entitled to a CNC as a local government unit (LGU) not covered by PD 1586, the City petitioned the Regional Trial Court (RTC) of Davao City (Civil Case No. 28,133-2000) for a writ of mandamus and for injunctive rel Case Digest (G.R. No. 148622) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- Petitioners: Republic of the Philippines, represented by DENR Secretary Heherson T. Alvarez, DENR–Region XI RED Clarence L. Baguilat, and DENR–EMB Region XI Director Bienvenido L. Lipayon.
- Respondent: City of Davao, represented by Mayor Benjamin C. De Guzman.
- RTC of Davao City, Branch 33, granted City’s petition for writ of mandamus and injunction directing DENR to issue a Certificate of Non-Coverage (CNC); DENR’s motion for reconsideration was denied; DENR filed petition for certiorari to the Supreme Court.
- Application for Certificate of Non-Coverage
- August 11, 2000: City of Davao applied for CNC for its proposed Artica Sports Dome, submitting a detailed location map, project description, and City Planning and Development Office certification that the site is not in an environmentally critical area (ECA).
- EMB Region XI denied the application, finding the project within an ECA and requiring compliance with the Environmental Impact Statement (EIS) System under PD 1586 and PD 1151 to secure an Environmental Compliance Certificate (ECC).
- Trial Court Findings
- The RTC ruled that Local Government Units (LGUs) are excluded from PD 1586’s coverage because they are not national government agencies or private entities, invoking expressio unius est exclusio alterius.
- Based on certifications from DENR-CENRO West and PHIVOLCS, the court found the project neither within an ECA nor an environmentally critical project, thus mandating issuance of the CNC as a ministerial act.
Issues:
- Whether a Local Government Unit is excluded from the coverage of PD 1586 and thus not required to secure an ECC but entitled only to a CNC.
- Whether the Artica Sports Dome project is an environmentally critical project or located in an environmentally critical area, thereby triggering the EIS requirements and ECC.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)