Case Digest (G.R. No. 191427) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Universal Robina Corp. (Corn Division) v. Laguna Lake Development Authority, petitioner Universal Robina Corporation (URC), an animal feed and corn oil refinery operator in Bagong Ilog, Pasig City, was repeatedly found after laboratory analyses on March 14, 2000 and August 31, 2000 to have discharged effluents exceeding the parameters for Total Suspended Solids, Biochemical Oxygen Demand, Color, and Oil/Grease under DENR Administrative Orders Nos. 34 and 35, series of 1990. On May 30, 2000, the LLDA issued an ex parte show cause order for URC’s lack of an LLDA permit and pollutive discharges into the Pasig River. After hearings beginning March 1, 2001 and further inspections revealing continued violations, URC undertook an upgrade of its wastewater treatment facility, completed only in 2007. A re-sampling on May 9, 2007 confirmed compliance, prompting URC on August 24, 2007 to file a motion seeking reduction of penalties to reflect only 560 operating days. On January 21, 2008 Case Digest (G.R. No. 191427) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Universal Robina Corp. (URC), petitioner, operates a corn oil refinery plant in Bagong Ilog, Pasig City, engaged in animal feed manufacture.
- Laguna Lake Development Authority (LLDA), respondent, oversees pollution control under DENR Administrative Orders (DAOs) Nos. 34 and 35, series of 1990.
- LLDA’s Monitoring and Initial Proceedings
- March 14, 2000: LLDA laboratory analysis finds URC’s wastewater non-compliant with effluent standards (TSS, BOD, color, oil/grease); May 30, 2000: ex-parte order to show cause for cessation of operations and lack of LLDA permit.
- August 31, 2000: follow-up sampling upon complaint confirms continued violations; hearings commenced March 1, 2001; subsequent monitoring still revealed non-compliance.
- URC’s Remedial Measures and Re-sampling
- Early 2003: URC undertakes upgrade of its wastewater treatment facility (WTF); completion only in 2007.
- May 9, 2007: re-sampling shows compliance; August 24, 2007: URC files motion attaching Daily Operation Reports and Certifications claiming only 560 days of actual discharge violations.
- LLDA Orders and Calculations of Penalties
- January 21, 2008 Order to Pay (OP): penalties computed for two periods—March 14, 2000 to November 3, 2003 (932 days) and March 15, 2006 to April 17, 2007 (448 days)—totaling 1,247 days → PHP 1,247,000.
- July 11, 2008 Resolution denying reconsideration: LLDA clarifies deduction of 212-day lab rehabilitation gap and an unmonitored interval of over two years; revises second period to 342 days; total 1,274 days.
- Court of Appeals Proceedings
- URC’s petition for certiorari challenges LLDA’s disregard of its documentary evidence and asserts absence of plain, speedy, adequate remedy.
- October 27, 2009 CA Decision: affirms LLDA orders—computation consistent with DENR guidelines; LLDA reasonably deemed URC’s unverified reports self-serving; CA dismisses for failure to exhaust administrative remedies.
- February 23, 2010 Resolution: denies URC’s motion for reconsideration; petitioner elevates to the Supreme Court.
Issues:
- Whether LLDA gravely abused its discretion in computing and imposing daily penalties by excluding or including certain days and disregarding URC’s documentary proof of non-operation.
- Whether URC’s alleged lack of plain, speedy, and adequate remedy, and asserted due process violations, excuse its failure to exhaust administrative remedies before seeking judicial relief.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)