Case Summary (G.R. No. 120865-71)
Petitioner and Respondents
Petitioner: Laguna Lake Development Authority
Respondents: The Court of Appeals; presiding RTC judges; private fishpen operators; Municipalities of Binangonan, Taguig, Jala-Jala, and their respective mayors
Key Dates
– LLDA charter enacted: Republic Act No. 4850 (1966)
– Amendments by PD 813 (1975) and EO 927 (1983)
– Local Government Code enacted: RA No. 7160 (1991)
– LLDA notice declaring unregistered fishpens illegal: June–July 1993
– Injunction suits filed: 1993–1994
– Court of Appeals decision dismissing LLDA petitions: June 29, 1995
– Supreme Court resolution referring petitions to CA: May 2, 1994
– Supreme Court decision: December 7, 1995
Applicable Law
– 1987 Philippine Constitution (environmental protection, devolution of powers)
– Republic Act No. 4850, as amended by Presidential Decree No. 813 and Executive Order No. 927 – LLDA charter granting exclusive jurisdiction over Laguna de Bay water uses
– Republic Act No. 7160 (Local Government Code of 1991) – general law granting municipalities exclusive authority to grant municipal fishery privileges
Factual Background
Unregulated municipal permits led to explosive growth of fishpens and fishcages—from about 7,000 hectares in 1990 to 21,000 hectares in 1995—aggravating pollution and ecological stress in Laguna de Bay. LLDA, invoking its charter powers, declared all unregistered aquaculture structures illegal and ordered their demolition. Affected operators sought injunctive relief in various RTC branches, which issued temporary restraining orders and preliminary injunctions against LLDA. LLDA’s motions to dismiss for lack of jurisdiction were denied.
Procedural History
LLDA filed consolidated petitions for certiorari, prohibition, and injunction with the Supreme Court, challenging RTC jurisdiction and asserting its exclusive authority. The Supreme Court referred the matter to the Court of Appeals, which dismissed LLDA’s petitions. The CA held that (a) LLDA is not a quasi-judicial body whose orders are appealable only to the CA; (b) LLDA’s fishery-permit powers had been repealed by the Local Government Code; and (c) permit-granting authority devolved to municipalities.
Issue
Whether RA 7160 (Local Government Code) repealed LLDA’s exclusive power under RA 4850, PD 813, and EO 927 to issue permits for fishpens, fishcages, and other aquaculture structures in Laguna de Bay.
Rationale
- Special versus General Law: LLDA’s charter is a special law; RA 7160 is a general law. Under established rules of statutory construction, a subsequent general law does not repeal a special law by implication. No express repeal of LLDA’s charter appears in RA 7160, and legislative intent to repeal is lacking.
- Integrated Ecosystem Management: Laguna de Bay and its watershed form a single ecological unit requiring uniform policies. Fragmented local control undermines sustainable development, water-quality management, and flood control.
- Police Power and Regulatory Authority: LLDA’s permit powers are an exercise of police power to regulate activities affecting the lake’s ecology and quality. These powers prevail over municipal revenue-raising permits, which are limited to municipal water areas and organized under the taxing provisions of RA 7160.
- Quasi-Judicial Character: LLDA’s charter and prior decisions confirm its quasi-judicial authority to issue cease-and-desist orders and adjudicate environmental violations. However, LLDA is not co-equal with the RTCs—jurisdictional questions and permit disputes may be litigated in RTCs.
Holding
– RA 7160 did n
Case Syllabus (G.R. No. 120865-71)
Facts
- The Laguna Lake Development Authority (LLDA) was created under Republic Act No. 4850 to promote, accelerate and balance the growth of the Laguna Lake region with due regard for environmental management, human life quality and ecological systems.
- Presidential Decree No. 813 amended RA 4850 to address rapid urbanization, pollution from the Pasig River and lakeshore areas, flood control issues and the need for improved water quality standards.
- Executive Order No. 927 further enlarged LLDA’s functions, affirmed its exclusive jurisdiction over surface‐water permits in the Laguna de Bay Region and prescribed a fee‐sharing scheme (75% LLDA, 20% lakeshore LGUs, 5% project fund).
- Section 41(11) of PD 813 defined “Laguna Lake” as the area covered by lake waters at an average annual maximum elevation of 12.50 m (datum 10 m below mean lower low water).
- Republic Act No. 7160 (Local Government Code of 1991) granted municipalities exclusive authority to issue fishery privileges and collect fees in their municipal waters (Sec. 149, Sec. 447).
- By 1995, unregulated fishpens and fishcages occupied about 21,000 hectares of the 900 km² lake (up from 7,000 ha in 1990), aggravating environmental stress.
- LLDA declared all unregistered or unpermitted fishpens as illegal (Notice, June 1993), ordered owners to show cause by October 27, 1993, and warned of demolition and criminal charges under Sec. 39A of RA 4850 as amended.
- Lakeshore municipalities continued issuing Mayor’s permits for fishpens in violation of LLDA zoning and carrying‐capacity policies. Fishpen operators secured TROs and preliminary injunctions from various RTC branches.
Legislative and Legal Background
- Republic Act No. 4850 (1957): Created LLDA; national policy for regional development with environmental safeguards.
- Presidential Decree No. 813 (1975): Amended RA 4850 to strengthen LLDA’s environmental, pollution‐control and water‐rights powers.
- Executive Order No. 927 (1983): Defined the “Laguna de Bay Region,” reaffirmed LLDA’s exclusive water‐permit jurisdiction, and established fee‐sharing rules.
- PD 813, Sec. 41(11): Defined “Laguna Lake” as public lands forming the lake bed up to a specified elevation.
- Republic Act No. 7160 (1991): General law granting municipalities exclusive fishery‐permit authority in municipal waters and placing that power under LGU revenue‐raising provisions (Book II, Ch. 2).
Procedural Posture
- Affected fishpen owners filed multiple suits (prohibition, injunction, certiorari, declaratory relief) in RTC branches of Binangonan, Pasig and Morong.
- LLDA’s motions to dismiss for lack of jurisdiction were denied by the RTCs; TROs and preliminary injunctions