Case Summary (G.R. No. 156686)
Applicable Law and Resolution Background
Under the Local Government Code of 1991 (Republic Act No. 7160), specifically Section 21, local government units (LGUs) such as barangays may temporarily or permanently close or open local roads by ordinance, subject to certain procedural requirements. Barangay Sun Valley issued Resolution No. 98-096 directing NSVHAI to open private subdivision roads during specified hours, citing its authority under the Local Government Code.
Petitioner's Claims and RTC Proceedings
NSVHAI filed a petition for a writ of preliminary injunction to restrain the implementation of the Barangay resolution, asserting that the roads were private, acquired for strictly residential purposes, and opening them to public traffic would cause irreparable harm including loss of privacy, peace, and security. They argued the subdivision roads and drainage were not designed for heavy or public traffic and that alternative routes could alleviate local congestion. The petitioner also contended that a barangay resolution was insufficient for opening these roads, as an ordinance is legally required.
The Regional Trial Court (RTC) initially issued a temporary restraining order (TRO) and later a preliminary injunction to maintain the status quo. However, the RTC eventually dismissed the case on grounds that the barangay had jurisdiction over the roads, which were public property donated to the local government, and that the petitioner had not exhausted administrative remedies under Sections 32 and 57 of the Local Government Code. The dismissal was based on the fact that only local government units can open or close roads by ordinance, and ownership of the roads had already vested in the municipality of Parañaque.
Procedural Issues on Motion to Dismiss
The petitioner raised procedural due process concerns, asserting the RTC ruled on the motion to dismiss without conducting a hearing or giving them the chance to comment. It argued that its amended petition, filed before the respondents' motion, superseded the original complaint, rendering the motion to dismiss moot. The petitioner maintained that it was deprived of due process because no hearing nor order for comment on the motion to dismiss was issued.
Respondents' Position and Supporting Evidence
Respondents argued the roads in question had been donated to and titled in the name of the municipal government since the 1960s, supported by multiple certificates and legal opinions issued by the Parañaque Office of the Municipal Attorney. They contended the barangay resolution was a valid exercise of its authority to manage local traffic problems and was more a temporary administrative directive than a legislative ordinance. Respondents also maintained that the petitioner had no legal right to control public roads, that closing them with gates was illegal, and that the issue was primarily a local government function subject to the Mayor’s general supervision.
Moreover, they asserted the petitioner failed to exhaust administrative remedies by bypassing the Mayor’s supervisory authority and filing suit prematurely.
Court of Appeals' Findings
The Court of Appeals affirmed the dismissal of the petition, ruling that the petitioner was not denied due process. It found that although no specific hearing date and time was set for the motion to dismiss, the issues were heard concurrently with the preliminary injunction proceedings, where both parties were present and given opportunity to argue. The Court noted the petitioner’s failed attempts to establish ownership and emphasized that the roads had been donated to and were owned by the City Government of Parañaque.
The Court underscored that under Section 21 of the Local Government Code, local roads may be opened or closed only by ordinance, but since the roads were public property, this control vested in the local government, not the homeowners' association. Consequently, the barangay's resolution was valid as a directive to open public roads for traffic decongestion.
Doctrine of Exhaustion of Administrative Remedies
The Supreme Court upheld the doctrine that administrative remedies must be exhausted before resorting to the courts. Since the Local Government Code grants the city mayor supervisory power over barangays, the petitioner should have sought relief through mayoral intervention instead of initiating judicial action. The Court emphasized that this process promotes efficient resolution and respects local government autonomy.
Burden of Proof on Ownership and Legal Rights
The petitioner bore the burden to prove its claimed rights and ownership over the roads to justify injunctive relief. The Court found that no substantial evidenc
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Factual Background and Nature of the Dispute
- The Sangguniang Barangay of Barangay Sun Valley ("BSV Sangguniang Barangay") passed Resolution No. 98-096 on October 13, 1998, directing the New Sun Valley Homeowners Association, Inc. (NSVHAI) to open Rosemallow and Aster Streets to vehicular and pedestrian traffic during certain hours.
- The resolution allowed closure of these streets from 11 p.m. to 5 a.m. for security reasons.
- NSVHAI opposed the resolution, claiming grave injustice and irreparable injury as the subdivision was strictly residential, valuing privacy and peaceful ambiance.
- NSVHAI argued that opening the streets would worsen traffic congestion rather than alleviate it, jeopardize security, and damage subdivision roads and drainage systems not designed for heavy or public use.
- NSVHAI maintained proprietary rights over the roads, contending that as homeowners they had paid for such roads and parks and had an equity interest.
- NSVHAI filed a petition for writ of preliminary and permanent injunction with the RTC to stop implementation of the resolution, asserting the barangay lacked jurisdiction and an ordinance, not a resolution, was required to open roads.
Proceedings in the Regional Trial Court (RTC)
- The RTC issued a temporary restraining order (TRO) on October 30, 1998, prohibiting implementation of the Barangay resolution for 72 hours.
- The TRO was extended by agreement of the parties for 17 more days.
- NSVHAI filed an Amended Petition on November 13, 1998, arguing the barangay lacked jurisdiction and that an ordinance was necessary.
- BSV Sangguniang Barangay filed a Motion to Dismiss on the same day.
- The RTC heard the case on November 20, 1998, primarily considering the injunction petition and motion to dismiss.
- On the same date, the RTC issued a writ of preliminary injunction, preventing implementation of the resolution, subject to posting of bond by NSVHAI.
- Respondents filed a motion for reconsideration and to dissolve the preliminary injunction on December 4, 1998.
- NSVHAI contested the motion to reconsider as filed out of time and challenged the refusal to rule on it.
- On August 17, 1999, the RTC dismissed the case for lack of cause of action and lack of jurisdiction, holding the streets belonged to the government and that under the Local Government Code (R.A. 7160), only local government units could open or close roads pursuant to ordinance.
- The RTC also found NSVHAI failed to exhaust administrative remedies under Sections 32 and 57 of the Local Government Code.
- NSVHAI’s motion for reconsideration was denied on September 21, 1999.
Court of Appeals Proceedings and Ruling
- NSVHAI appealed to the Court of Appeals, docketed as CA-G.R. CV No. 65559.
- NSVHAI argued the RTC erred in dismissing the case without hearing or opportunity to oppose the motion to dismiss, and contended the court ruled beyond the pleadings by relying on evidentiary matters not in the record.
- NSVHAI contended their right to a hearing was denied and that the sale of subdivision lots and roads vested ownership in the homeowners association.
- Respondents argued the motion to dismiss was proper and undisputed, that the roads were already public property owned by the Parañaque City government as shown by certificates of title and official certifications attached to their brief, not contested by NSVHAI.
- Respondents maintained the barangay had sole competence to address local traffic problems and that the resolution was a valid directive, not legislative in nature so no ordinance was required.
- The Court of Appeals affirmed the dismissal and denial of reconsideration, finding the RTC acted properly and due process was observed.
- The appellate court held that the subject roads were public roads donated to and recorded in the name of Parañaque since 1964, and thus beyond the proprietary claims of NSVHAI.
- It ruled NSVHAI’s failure to exhaust administrative remedies, specifically appealing to the city mayor under Section 32 of the Local Government Code, barred judicial intervention.
- The appellate court stated the Local Government Code empowers LGUs to open or close roads by ordinance but that requirement did not apply where the roads were public and under city ownership.
- The CA found NSVHAI failed to prove ownership or proprietary rights necessary to entitle them to injunctive relief.
- The CA concluded the barangay resolution was a legitimate exercise of local government function to solve traffic concerns and not subject to judicial interference absent grave abuse of discretion.
Legal Issues Presented
- Whether the Regional Trial Court departed from usual judicial proceedings and violated due process by granting respondents' Motion to Dismiss without proper hearing.
- Whether Sections 32 and 57 of the Local Government Code mandating exhaustion of administrative remedies before judicial recourse were applicable and properly invoked.
- Whether the barangay resolution was validly issued by the Sangguniang Barangay or if an ordinance was legally required to open the roads.
- Whether the roads subject to the dispute were private property owned by NSVHAI or public roads owned by the City Government of Parañaque.
- The scope and limits of barangay and local government authority regarding closure and opening of roads within their jurisdiction.
- The burden of proof regarding ownership and right to injunctive relief.
Pertinent Legal Principles and Statutory Framework
- Local Government Code (R.A. 7160), Section 21: Grants LGUs power to open or close local roads by ordinance.
- Local Government Code, Section 32: Provides the city/municipal mayor’s power to supervise barangays and review their acts for jurisdictional compliance.
- Doctrine of Exhaustion of Administrative Remedies: Courts require aggrieved parties to seek administrative relief before filing judicial actions to allow administrative bodies to resolve disputes expeditiously and ec