Case Digest (G.R. No. 85502)
Facts:
Sunville Timber Products, Inc. v. Hon. Alfonso G. Abad as Judge, RTC, Br. 22 of Pagadian City, Court of Appeals, Isidro Gilbolingo and Robustiano Bugtai, G.R. No. 85502, February 24, 1992, the Supreme Court First Division, Cruz, J., writing for the Court.The petitioner, Sunville Timber Products, Inc., held a Timber License Agreement (TLA) authorizing logging over a 29,500-hectare concession in Zamboanga del Sur for ten years, expiring September 31, 1992. On July 31, 1987, private respondents Isidro Gilbolingo and Robustiano Bugtai filed with the Department of Environment and Natural Resources (DENR) a petition to cancel the TLA for serious violations of its terms and forestry laws. The same private respondents thereafter filed Civil Case No. 2732 (a complaint for injunction with damages) in the Regional Trial Court (RTC) of Pagadian City alleging unlawful logging and attendant environmental harm.
Sunville moved to dismiss the RTC complaint on three grounds: lack of jurisdiction, failure to exhaust administrative remedies, and that the sought injunction was prohibited by Section 1 of PD 605. The RTC (Judge Alfonso G. Abad) denied the motion to dismiss on December 11, 1987, and denied reconsideration on February 15, 1988. The petitioner elevated the matter to the Court of Appeals, which affirmed the RTC in a decision dated July 4, 1988 and denied reconsideration on September 27, 1988. The Court of Appeals held that exceptions to the doctrine of exhaustion of administrative remedies applied (notably urgent need for judicial intervention and irreparable damage) and, in addition, declared Section 1 of PD 605 unconstitutional as an encroachment on the judiciary.
Petitioner brought the matter to the Supreme Court seeking relief from the RTC and Court of Appeals rulings. The record before the Court also showed that the DENR had, by telegram dated February 22–23, 1988, ordered th...(Subscriber-Only)
Issues:
- Whether the doctrine of exhaustion of administrative remedies barred the private respondents’ civil complaint and whether any recognized exceptions justified immediate judicial intervention.
- Whether Section 1 of Presidential Decree No. 605 is unconstitutional insofar as it bars courts from issuing preliminary injunctions in cases involving administrative actions on g...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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