Case Summary (G.R. No. 175039)
Background of the Case
Megaworld Properties was the registered owner of a parcel of land in Addition Hills, Mandaluyong City, and had begun planning the development of the Wack-Wack Heights Condominium. The company secured various clearances necessary for the construction, including a Certificate of Locational Viability (CLV), Development Permit, Environmental Compliance Certificate (ECC), Building Permit, and Barangay Clearance. The AHMCSO later filed a complaint seeking the annulment of these permits on the grounds of their alleged impropriety and non-compliance with zoning regulations.
Proceedings in Regional Trial Court
Following the filing of the complaint against Megaworld's permits, the Regional Trial Court (RTC) of Pasig issued a decision on September 10, 1998, ruling in favor of AHMCSO. The RTC declared the permits issued to Megaworld void, ordering the company to rectify its project in accordance with the residential zoning requirements of Mandaluyong City.
Appellate Review by the Court of Appeals
Megaworld appealed the RTC's ruling to the Court of Appeals, which issued a decision on May 16, 2006, reversing the trial court's judgment and dismissing the complaint filed by AHMCSO. The Court of Appeals reasoned that AHMCSO had failed to exhaust the available administrative remedies before seeking judicial intervention.
Legal Issues Presented
The petitioner raised several issues, including whether the Court of Appeals erred in finding that AHMCSO did not exhaust administrative remedies and whether the HLURB had jurisdiction over the matters involved. Megaworld also contended that the petition for review was fatally defective for being improperly verified, and that the trial court's decision contradicted established laws and facts.
Exhaustion of Administrative Remedies
The Supreme Court emphasized the principle of exhaustion of administrative remedies, which mandates that individuals must first pursue all available remedies within the administrative framework before seeking judicial intervention. Here, AHMCSO failed to present the matter to the HLURB, which had the authority to review the legality of the permits in question.
Findings of the Supreme Court
The Supreme Court affirmed the Court of Appeals’ ruling, holding that AHMCSO did not exhaust its administrative remedies, as the proper course would have involved filing a complaint before the Housing and Land Use Arbiter (HLA).
...continue readingCase Syllabus (G.R. No. 175039)
Case Citation
- G.R. No. 175039
- Date: April 18, 2012
- Court: First Division, Supreme Court of the Philippines
- Jurisprudence Reference: 686 Phil. 76
Parties Involved
- Petitioner: Addition Hills Mandaluyong Civic & Social Organization, Inc. (AHMCSO)
- Respondents:
- Megaworld Properties & Holdings, Inc.
- Wilfredo I. Imperial, in his capacity as Director, NCR
- Housing and Land Use Regulatory Board (HLURB), Department of Environment and Natural Resources
Background of the Case
- The case arises from a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure regarding the Decision dated May 16, 2006, and the Resolution dated October 5, 2006, of the Court of Appeals in CA-G.R. CV No. 63439.
- The appellate court reversed the September 10, 1998 Decision of the Regional Trial Court (RTC) of Pasig City, Branch 158, in Civil Case No. 65171.
Facts of the Case
- Ownership: Megaworld was the registered owner of a 6,148 square meter parcel of land along Lee Street, Barangay Addition Hills, Mandaluyong City, covered by TCT No. 12768.
- Project Development: In 1994, Megaworld planned to construct the Wack-Wack Heights Condominium, consisting of six four-storey buildings and one seventeen-storey tower.
- Permits Secured: Megaworld obtained various necessary permits:
- Certificate of Locational Viability (CLV) - October 25, 1994
- Development Permit - November 11, 1994
- Environmental Compliance Certificate (ECC) - March 15, 1995
- Building Permit - February 3, 1995
- Barangay Clearance - September 29, 1994
- Complaint Filed: On June 30, 1995, AHMCSO filed a complaint in RTC Pasig for the annulment