One Heart Sporting Club, Inc. v. Court of Appeals
REITERATIONFacts
The Antecedents: Presidential Decree No. 449 (Cockfighting Law of 1974) required cockpits to be constructed and operated within appropriate zoning areas, granting a three-year period for existing non-conforming cockpits to comply. This period was extended by Presidential Decree No. 1140 for another year, expiring on May 9, 1978. Private respondent, Dipolog Coliseum, Inc., operated a cockpit within a prohibited area. On May 10, 1978, petitioner One Heart Sporting Club, Inc. applied for a permit to construct a new cockpit. A mayor's permit was granted and approved by the PC Regional Commander on September 19, 1978. Sporting Club was incorporated on the same day and commenced operations on September 24, 1978. On June 11, 1978, Presidential Decree No. 1535 was issued, extending for another two years from its effectivity date (June 11, 1978) the period for existing cockpits to relocate within permissible areas, until June 11, 1980. Private respondent requested to resume operations, which was granted by the City Mayor but denied by the PC Provincial Command, citing that only one cockpit could operate in the city pursuant to Section 5(b) of P.D. 1535. Procedural History: Private respondent filed a case before the Court of First Instance (CFI) for declaratory relief, prohibition, mandamus, annulment, and damages with preliminary injunction. The CFI dismissed the complaint and granted damages to Sporting Club. Private respondent then filed a petition for certiorari, prohibition, mandamus with preliminary injunction before the Court of Appeals (CA). The CA set aside the CFI decision and ordered the PC Command to allow Dipolog Coliseum, Inc. to resume operation of its cockpit and to transfer to an appropriate location prior to June 11, 1980. Sporting Club filed a motion for reconsideration before the CA. Before the CA could rule, Sporting Club filed a petition for certiorari and prohibition with preliminary injunction before the Supreme Court (SC) (G.R. No. 53790). The SC issued a temporary restraining order. The CA denied the motion for reconsideration. Sporting Club then filed a petition for review on certiorari before the SC (G.R. No. 53972). The Petition: The SC consolidated G.R. Nos. 53790 and 53972. Petitioners (Sporting Club and Angeles B. Cuenca) sought to set aside the CA decision, raising issues of jurisdiction, entitlement to the extension under P.D. 1535, and fairness/equity. They also argued that private respondent failed to exhaust administrative remedies and did not include a necessary party.
Issue(s)
Whether the Court of Appeals had jurisdiction over the special civil action for certiorari, prohibition, and mandamus. Whether private respondent Dipolog Coliseum, Inc. was entitled to the extension granted by Presidential Decree No. 1535. Whether private respondent failed to exhaust administrative remedies. Whether the Regional Philippine Constabulary Commander was a necessary party to the suit.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, granting Dipolog Coliseum, Inc. six (6) months from notice within which to transfer its cockpit to an appropriate location. The temporary restraining order issued by the Supreme Court was lifted.
Ratio Decidendi
On the jurisdiction of the Court of Appeals: The Court held that the Court of Appeals had jurisdiction. Petitioners' argument that the case involved purely questions of law, thus precluding the CA from acting in aid of its appellate jurisdiction, was rejected. The Court noted that the CFI's award of damages involved questions of fact, which the CA could properly review. Furthermore, the petitioners themselves had urged the CA to elevate the records from the lower court and had submitted their memoranda without questioning the CA's authority until an adverse decision was rendered. The Court reiterated the principle that a party who voluntarily submits a case for decision and then questions the jurisdiction only after an unfavorable ruling is deemed to have waived such objection, citing Tejam vs. Sibonghanoy and Pindangan Agricultural Company, Inc. vs. Dans. On the entitlement to the extension under P.D. 1535: The Court ruled that private respondent was entitled to the extension granted by P.D. 1535. The decree was intended to grant an extension to cockpits still located within prohibited areas to relocate. The Court reasoned that P.D. 1535 would be rendered ineffective if not applied to cockpits like private respondent's, which were still legally in existence within the prohibited area when the decree took effect. The Court acknowledged that the late publication of P.D. 1535 caused confusion but emphasized that its intent was to cover cockpits granted an extension by P.D. 1140. On the exhaustion of administrative remedies: The Court held that the principle of exhaustion of administrative remedies was not applicable in this case because the dispute involved a purely legal question: the interpretation of Presidential Decrees concerning cockpit operations and extensions. Citing cases like Dauan vs. Secretary of Agriculture and Natural Resources and Mitra vs. Subido, the Court stated that when the question is purely legal, judicial redress may be sought directly, justifying private respondent's action. On the inclusion of a necessary party: While not explicitly addressed as a separate issue in the ratio, the Court's affirmation of the CA decision implies that the absence of the Regional Philippine Constabulary Commander did not divest the CA of jurisdiction or render its decision void, especially given the procedural posture of the case and the nature of the relief sought.
Main Doctrine
Presidential Decree No. 1535 extended the period for existing cockpits to comply with zoning requirements, and the Court of Appeals had jurisdiction over the case despite the petitioners' belated challenge.