Atis v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Nemesio N. Atis filed a Complaint for Judicial Abatement of Nuisance, Mandatory Injunction, and Damages against Orlando S. Delatina. Petitioner alleged that his fishpond, along with others, relied on a natural watercourse flowing from higher estates to the sea. Sometime in August 1986, the defendant constructed a dike on the land claimed by intervenors Spouses Arturo M. and Eleuteria (Lilian) B. Paculanang, thereby blocking the natural waterway. This obstruction caused the water in petitioner's fishpond to become stagnant, leading to the poisoning of his fish and causing him great and irreparable damage. Procedural History: The Regional Trial Court (RTC), Branch X, Dipolog City, initially issued a Temporary Mandatory Restraining Order directing the defendant to demolish the dike. The intervenors, claiming ownership of the property, filed an Answer-in-Intervention, asserting that the defendant was their caretaker and that the dike was constructed for an irrigation canal and served as a bridge for the community. The RTC appointed a Commissioner who recommended the immediate demolition of the dikes. Subsequently, the defendant filed a Motion to Dismiss, arguing that the RTC lacked jurisdiction over the subject matter, which he contended was vested in the National Water Resources Council (NWRC) under Presidential Decree No. 424, and that petitioner failed to exhaust administrative remedies. The RTC dismissed the case on the ground of failure to exhaust administrative remedies. The Court of Appeals affirmed the RTC's dismissal. The Petition: Petitioner appealed to the Supreme Court, arguing that the Court of Appeals erred in failing to consider that the main issue was whether the respondents' acts caused damage to petitioner's rights, not a dispute over water rights. He also contended that the case was an exception to the rule on exhaustion of administrative remedies and that the respondents could not question the RTC's jurisdiction after submitting to it.
Issue(s)
Whether the Regional Trial Court has jurisdiction over the subject matter of the case, considering the allegations of obstruction of a natural watercourse and resulting damages. Whether the doctrine of exhaustion of administrative remedies applies in this case.
Ruling
The Supreme Court ruled that the Regional Trial Court has jurisdiction over the case and set aside the decision of the Court of Appeals, remanding the case to the RTC for further proceedings. The Court held that the case does not involve a dispute relating to water rights appropriation or utilization, which falls under the original jurisdiction of the National Water Resources Council, but rather concerns the obstruction of a natural waterway and the resulting damages to the petitioner's property and rights.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the Regional Trial Court has jurisdiction over the instant case. The material allegations of the Complaint do not involve a dispute relating to the appropriation or use of waters as defined under Presidential Decree No. 1067, "The Water Code of the Philippines." "Appropriation" refers to the acquisition of rights over the use of waters or the taking or diverting of waters from a natural source, while "use of water for fisheries" is the utilization of water for the propagation and culture of fish as a commercial enterprise. The petitioner, in fact, holds water permits from the NWRC for his fishpond. The core issue presented was not about the petitioner's right to use water, but whether the construction of the dike obstructed the natural watercourse and caused injury to the petitioner's rights and impaired the use of his fishpond. This type of issue necessitates judicial intervention, as established in Amistoso v. Ang, where the enjoyment of a right emanating from a grant, violated by the closure of an irrigation canal, was the subject of litigation, and not a matter within the NWRC's jurisdiction. On the issue of exhaustion of administrative remedies: The Court ruled that the doctrine of exhaustion of administrative remedies does not apply in this case. Since the Regional Trial Court, and not the National Water Resources Council, has jurisdiction over the subject matter, there was no administrative remedy to exhaust. The dismissal of the case by both the RTC and the Court of Appeals on the basis of this doctrine was therefore erroneous. The case is fundamentally about the abatement of a nuisance and the recovery of damages resulting from the obstruction of a natural flow of water, which are matters cognizable by regular courts.
Main Doctrine
The Regional Trial Court, not the National Water Resources Council, has jurisdiction over a case involving the obstruction of a natural watercourse causing damage, as it does not involve a dispute over water rights appropriation or utilization under Presidential Decree No. 1067, but rather the enjoyment of rights emanating from a grant and the resulting injury.