Gabi Multi-Purpose Cooperative, Inc. v. Republic of the Philippines
REITERATIONFacts
The Antecedents: The Republic of the Philippines filed a Complaint for Annulment and Cancellation of Titles against several individuals and the Register of Deeds of Cebu City, alleging that certain parcels of land, titled under free patents, were part of the Sudlon National Park and thus public land, not alienable and disposable. The complaint was later amended to implead GABI Multi-Purpose Cooperative, Inc. (GABI) as a defendant, alleging that GABI purchased the subject parcels and constructed improvements within the park without authority, obstructing government policies and disrupting the ecological balance. Procedural History: Interventions were filed by minors and organizations asserting their right to a balanced ecology. The trial court granted a motion for a court-supervised relocation survey of the disputed lots and the Sudlon National Park. The DENR conducted the survey, and subsequently filed a Compliance with its Report. GABI filed an Objection to the Survey and a Motion to Constitute Commissioners. The trial court issued an Order requiring comments on GABI's motion and suspending the survey. However, the DENR surveyors had already completed the survey by the time the Order was received. The trial court, in an Order dated August 25, 2000, ruled that the relocation survey was irregularly conducted and scheduled a conference for another survey. The Republic filed a Petition for Certiorari with the Court of Appeals (CA). The Petition: The CA granted the Republic's petition, reversing and setting aside the trial court's August 25, 2000 Order for having been issued with grave abuse of discretion. The CA found no irregularity in the relocation survey and ruled that the trial court's reasons for invalidating it were capricious. GABI then filed the present Petition for Review.
Issue(s)
Whether the Court of Appeals gravely erred in declaring that the trial court acted with grave abuse of discretion in issuing the August 25, 2000 Order regarding the relocation survey. Whether the Court of Appeals gravely erred in disregarding the requirement to exhaust available remedies before filing a petition for certiorari. Whether the Court of Appeals gravely erred in declaring GABI's objection to the relocation survey and the denial of the report premature.
Ruling
The Supreme Court denied the Petition for Review and affirmed the Decision and Resolution of the Court of Appeals. The Court held that the trial court committed grave abuse of discretion in setting aside the relocation survey and ordering a new one without sufficient basis. The Court also found that the exceptions to the rule on exhaustion of remedies were applicable, justifying the Republic's resort to a petition for certiorari.
Ratio Decidendi
On the issue of the conduct of the relocation survey and the justification for another relocation survey: The Court held that the relocation survey conducted by the DENR was faithful to the trial court's September 14, 1999 Order. The Order directed the survey to be based on the technical description of the official government cadastral survey, and the DENR's use of additional references like the land classification map and the park map was deemed prudent and not contrary to the Order. The Court found no merit in GABI's claim that the survey should not have been conducted with additional references, as the trial court's order did not explicitly prohibit it and such references were necessary given the dispute over whether the land was alienable. The presumption of regularity in the performance of duties by government surveyors was upheld, and GABI's allegations of irregularity were unsubstantiated. The Court found no justification for the trial court's August 25, 2000 Order for another relocation survey, reasoning that requiring the Republic to spend for an unjustified second survey would be inequitable, especially since the first survey was conducted in accordance with the trial court's order. Furthermore, ordering a new survey would unduly delay the disposition of the case, which was paramount to public interest, particularly concerning the protection of watersheds and water supply. On procedural matters (exhaustion of remedies and prematurity of objection) and the issue of reasonable notice: The Court sustained the CA's decision to give due course to the petition for certiorari despite the Republic's failure to file a motion for reconsideration, citing exceptions to the rule, including urgent necessity and situations where a motion for reconsideration would be useless. The Court found that the circumstances of the case, particularly the trial court's declaration of the survey's invalidity and scheduling of a new one, warranted immediate action. The Court agreed with the CA that GABI received reasonable notice of the relocation survey. The Compliance dated October 18, 1999, which informed the parties of the survey scheduled for October 25, 1999, was received by GABI on October 19, 1999. This, coupled with the fact that the trial court had ordered the survey a month prior, provided ample time for GABI to prepare. On the issue of the trial court's order to suspend the survey: The Court found that the respondent and the surveyors learned of the trial court's November 12, 1999 Order to suspend the survey only after its completion. Therefore, they could not be faulted for not suspending the survey. The Court also stated that the survey's completion within a short period did not necessarily imply irregularity, especially with the use of modern methods. The Court also found GABI's objection to be too late, as it was raised only after the survey had started, despite ample opportunity to request court-appointed commissioners earlier.
Main Doctrine
A relocation survey faithfully conducted pursuant to a trial court order cannot be invalidated on an unsubstantiated allegation of irregularities. The trial court's act of setting aside such a survey and ordering a new one without sufficient basis constitutes grave abuse of discretion.