Title
Supreme Court
National Power Corp. vs. Abdo
Case
G.R. No. 215494
Decision Date
Mar 27, 2023
Marawi residents sued NPC for ecological and economic harm from hydro plants; SC ruled RTC lacked jurisdiction due to unpaid fees and improper class suit filing.

Case Summary (G.R. No. 215494)

Factual Background

The respondents, identified as part of the socio-economically disadvantaged sectors in the Islamic City of Marawi and Lanao del Sur, filed a class suit for damages against NPC and the National Transmission Corporation (TRANSCO). They alleged that the construction and operation of seven hydroelectric power plants in Lake Lanao constituted bad faith and negligence, adversely impacting their health, safety, and livelihood. The respondents argued that the operation of a regulatory dam at the Agus River had detrimental effects on local agriculture and fisheries while also causing power interruptions detrimental to their businesses and property.

Key Legal Issues and Contentions

NPC countered the claims by asserting that the respondents had not met the requirements for a valid class suit, particularly failing to pay requisite docket fees. They contended that the complaint was based on conjecture and lacked factual foundation. Following procedural developments, the RTC issued a writ of preliminary injunction favoring the respondents, which NPC attempted to appeal, but the RTC failed to act on this notice.

The Ruling of the RTC

The RTC, upon hearing an urgent ex-parte motion from the respondents, ordered NPC and LASURECO to refund significant amounts due to unauthorized charges imposed from 1991 to 2003, as well as legal and interest fees. NPC’s attempt to have this order reconsidered was denied by the RTC, prompting NPC to file a notice of appeal.

Interventions by the Court of Appeals

The first ruling by the CA on January 22, 2013, initially favored NPC by dismissing the RTC's resolutions for lack of jurisdiction; however, it later identified that this decision was rendered moot by a prior ruling of the CA 21st Division which had already annulled earlier orders of the RTC. Consequently, the CA remanded the case back to RTC for further proceedings.

Questions of Jurisdiction

Central to the Supreme Court's decision was whether the CA erred in remanding the case to the RTC. The Supreme Court found merit in NPC's argument, clarifying that the RTC lacked jurisdiction owing to the respondents' failure to pay the required docket fees, which is paramount for a court to acquire authority over a case. The Supreme Court reiterated that a proper determination on whether the complaint constituted a valid class suit had not been made by the RTC.

Final Decision

The Supreme Court concluded that the CA’s remand to the RTC was erroneous. The CA's earlier findings held that the complaint did not satisfy the requirements for a class suit, and since the CA 21st Division's rulin

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