Facts:

• Two consolidated petitions are involved: G.R. No. 183324 and G.R. No. 209748.
• In G.R. No. 183324, Spouses Jose and Corazon Rodriguez (Sps. Rodriguez) filed a Petition for Review on Certiorari under Rule 45 against the Housing and Land Use Regulatory Board (HLURB), Spouses John Santiago and Helen King (Sps. Santiago), Imelda Rogano (Rogano), and Spouses Bonie and Nancy Gamboa (Sps. Gamboa).
• They challenged the Resolutions dated January 7, 2008, and May 6, 2008, by the Court of Appeals (CA) in CA-G.R. SP No. 101644.
• In G.R. No. 209748, Spouses Dr. Amelito S. Nicolas and Edna B. Nicolas (Sps. Nicolas) filed a Petition for Indirect Contempt on November 22, 2013, against the Sps. Rodriguez and Edjie Manlulu (Manlulu).
• The dispute originated from a verified Complaint dated October 20, 2004, filed by Spouses Rustico and Erlinda Balbino (Sps. Balbino) and the Sps. Nicolas against the Sps. Rodriguez before the Regional Field Office III (RFO III) of the HLURB.
• The complaint was amended on November 4, 2004.
• The HLURB-RFO III issued a Writ of Preliminary Injunction/Cease and Desist Order against the Sps. Rodriguez on November 19, 2004.
• Another complaint involving similar issues was filed by the Sps. Santiago, Rogano, and the Sps. Gamboa on November 23, 2004, leading to a Temporary Restraining Order against the Sps. Rodriguez.
• These complaints were consolidated into HLURB Case Nos. REM-03-04-0051 and REM-03-04-0055.
• The case revolves around the Ruben San Gabriel Subdivision in Barangay Wakas, Bocaue, Bulacan, consisting of 20 residential lots and one road lot.
• The Sps. Rodriguez acquired 13 lots, including the road lot, and consolidated their titles, which was approved by the Land Management Services of the Department of Environment and Natural Resources (DENR) on February 2, 1998.
• The complainants, residents of the subdivision, argued that the road lot could not be closed or conveyed without court approval as it was subject to Republic Act No. 440.
• They alleged that the Sps. Rodriguez were taking control of the road lot by introducing diggings and construction for fencing, closing it for their exclusive use.
• The HLURB-RFO III ruled in favor of the complainants, ordering the Sps. Rodriguez to cease and desist from including the road lot in their title consolidation.
• The HLURB Board initially overturned this decision but later reinstated it upon reconsideration, stating that the road lot's conversion into a regular lot was not approved.
• The Sps. Rodriguez filed a Rule 65 Petition before the CA, which was dismissed for failing to exhaust administrative remedies.
• The Sps. Nicolas filed a Petition for Indirect Contempt against the Sps. Rodriguez and Manlulu for allegedly defying the HLURB's Cease and Desist Order.

Issue:

• (Unlock)

Ruling:

1. The CA did not err in dismissing the Sps. Rodriguez' Rule 65 Petition.
2. The Petition for Indirect Conte...(Unlock)

Ratio:

1. The CA's dismissal of the Sps. Rodriguez' Rule 65 Petition was upheld because the Sps. Rodriguez failed to exhaust available administrative remedies by not appealing the HLURB Board's resolutions to the Office of the President (OP). The Rules of Procedure of the HLURB require that any party may appeal a decision rendered by the Board of Commissioners to the OP within fifteen days from receipt thereof. The Sps. Rodriguez did not provide any justification for their failure to seek prior rec...continue reading