Polomolok Water District v. Polomolok General Consumers Association
REITERATIONFacts
The Antecedents: The Polomolok Water District (PWD), a government-owned corporation, enacted Resolution No. 94-023 in October 1994, imposing new and higher water rates. The Polomolok General Consumers Association, Inc. (PGCA), a non-stock, non-profit corporation, and its members opposed these increased rates, alleging that the PWD failed to comply with mandatory notice and hearing requirements under Presidential Decree No. 198, as amended. Procedural History: The PGCA initially filed an administrative complaint with the National Water Resources Board (NWRB), which was dismissed for being filed out of time. Subsequently, the PGCA filed a class suit with the Regional Trial Court (RTC) seeking the nullity of PWD Resolution No. 94-023. The RTC issued a preliminary injunction enjoining the PWD from disconnecting water supply. Despite a Memorandum of Agreement between the parties, violations occurred. The RTC later issued another writ of preliminary injunction, which the PWD challenged via a petition for certiorari with the Court of Appeals (CA). The CA affirmed the RTC's orders and remanded the case for resolution, holding that the issue of the resolution's validity was incapable of pecuniary estimation, thus rendering the doctrine of exhaustion of administrative remedies inapplicable. The Petition: The PWD filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to reverse the CA's decision. The PWD contends that the RTC lacked jurisdiction because the PGCA failed to exhaust administrative remedies, arguing that the NWRB, not the RTC, had primary jurisdiction over the dispute concerning water rates. The PWD asserts that the CA erred in finding the issue incapable of pecuniary estimation and in affirming the RTC's issuance of preliminary injunctions.
Issue(s)
Whether the RTC committed grave abuse of discretion amounting to lack or excess of jurisdiction in issuing the writ of preliminary injunction. Whether respondent failed to exhaust all administrative remedies before seeking judicial relief. Whether the RTC has jurisdiction over Civil Case No. 281.
Ruling
The petition is denied. The assailed Decision of the Court of Appeals is affirmed. Costs against the petitioner.
Ratio Decidendi
On the issue of grave abuse of discretion in issuing the writ of preliminary injunction: The Court found that the respondent's complaint clearly stated that the case was based solely on the legality of the adoption of Resolution No. 94-023, and that the NWRB itself had previously resolved that it had no jurisdiction to pass on the legality of the resolution, further supporting the RTC's jurisdiction. Consequently, the RTC did not commit grave abuse of discretion in taking cognizance of the case and issuing the writ of preliminary injunction. On the issue of exhaustion of administrative remedies and jurisdiction: The Court reiterated the well-settled principle that the jurisdiction of a court is determined by the material allegations of the complaint and the character of the relief prayed for, irrespective of whether the plaintiff is entitled to such relief. In Civil Case No. 281, the core issue raised by the respondent was the validity of PWD Resolution No. 94-023, S. 1994, specifically alleging non-compliance with the requisites of notice, publication, and public hearing as mandated by P.D. No. 198, as amended. The relief sought was the declaration of nullity of the said resolution. The doctrine of exhaustion of administrative remedies, which requires parties to pursue all available administrative remedies before resorting to judicial action, is inapplicable in cases where the subject matter is incapable of pecuniary estimation, as it falls squarely within the exclusive original jurisdiction of the RTC. On the issue of RTC jurisdiction: The Court affirmed the Court of Appeals' holding that the subject of the litigation, which is the validity of the resolution imposing water rates, is incapable of pecuniary estimation. Section 19 of Batas Pambansa Blg. 129 provides that Regional Trial Courts shall exercise exclusive original jurisdiction in all civil actions where the subject of litigation is incapable of pecuniary estimation. The Court found that the respondent's complaint clearly stated that the case was based solely on the legality of the adoption of Resolution No. 94-023, and that the NWRB itself had previously resolved that it had no jurisdiction to pass on the legality of the resolution, further supporting the RTC's jurisdiction.
Main Doctrine
The Regional Trial Courts have exclusive original jurisdiction over civil actions where the subject of litigation is incapable of pecuniary estimation, such as the validity of a resolution imposing water rates, even if administrative remedies were not fully exhausted, as the doctrine of exhaustion of administrative remedies is inapplicable in such cases.