Laya v. Triviño
REITERATIONFacts
The Antecedents: Respondents Edwin and Lourdes Triviño own a residential unit in La Pacita Complex Subdivision, San Pedro, Laguna, which they have utilized as a mini-grocery store since 1987. By 2000, the store occupied over half of their residence, necessitating renovations. The Triviños obtained a Zoning Certification, a Homeowners Association endorsement, a Barangay Construction Clearance, a Tax Declaration, and a Fire Station endorsement before commencing construction. Procedural History: In July 2000, other homeowners in the subdivision objected to the construction, alleging it violated the San Pedro Zoning Ordinance. Instead of appealing to the Local Zoning Board of Appeal, they filed a complaint with the Municipal Mayor's Office. Realizing the futility of this, they filed a Petition/Appeal with the HLURB Regional Field Office in January 2001, asserting the construction of a commercial building in a residential zone was prohibited. The HLURB Regional Field Office dismissed this appeal. The homeowners then filed a Verified Petition for Review with the HLURB Board of Commissioners, which issued a Temporary Restraining Order, later made permanent, enjoining commercial activities beyond those previously existing and compatible with the residential zone, conditioned on the homeowners posting a bond. The homeowners' motion for reconsideration was denied. Subsequently, the homeowners filed a special civil action for certiorari with the Court of Appeals (CA), arguing the HLURB lacked jurisdiction. The CA granted the petition, setting aside the HLURB's order and dismissing the case for lack of merit. The CA denied the homeowners' motion for reconsideration. The Petition: Petitioners, Nestorito W. Laya and Rudy Martin (the homeowners), seek review of the CA's decision and resolution via a Petition for Review on Certiorari under Rule 45 of the Rules of Court. They argue the CA erred in ruling that their petition with the HLURB was filed in the wrong forum and beyond the reglementary period, that they challenged the Zoning Certification late, that their petition was an afterthought, that the Zoning Administrator's decision became final and executory, and that they failed to prove the construction violated the Zoning Ordinance. Petitioners contend the respondents are estopped from questioning HLURB's jurisdiction due to their active participation in the proceedings and that HLURB has jurisdiction under Executive Order No. 648 and its own rules. They also argue the Zoning Certification was not the appealable Certificate of Zoning Compliance and that in the absence of a Zoning Appeals Board, appeals should go directly to HLURB. Furthermore, they claim a Work Stoppage Order was issued and never lifted, preventing the Zoning Administrator's decision from becoming final.
Issue(s)
Whether the Court of Appeals gravely erred in ruling that the petition filed by petitioners with the HLURB Regional Field Office was lodged in the wrong forum and beyond the reglementary period, and whether respondents are estopped from questioning the jurisdiction of the HLURB Regional Field Office. Whether the Court of Appeals gravely erred in finding that the petitioners challenged the Zoning Certification only on January 12, 2001, or after more than five (5) months after receipt of the notice, thereby making the decision of the Zoning Administrator final and executory; and whether the filing of the petition was an afterthought. Whether the Court of Appeals gravely erred in finding that the petitioners failed to prove that the construction is in violation of the Zoning Ordinance of San Pedro, Laguna.
Ruling
The Supreme Court granted the petition, reversed and set aside the Decision and Resolution of the Court of Appeals, reinstated the Order of the HLURB Board of Commissioners dated May 30, 2001, and ordered the HLURB Board to proceed with reasonable dispatch in hearing the merits of petitioners' Verified Petition For Review.
Ratio Decidendi
On the issue of jurisdiction and estoppel: The Supreme Court held that respondents are estopped from questioning the jurisdiction of the HLURB Regional Field Office. The Court noted that respondents actively participated in all stages of the case before the Regional Field Office without raising objections to its jurisdiction. While a jurisdictional question may be raised at any time, this admits of an exception where estoppel has supervened. By voluntarily submitting to the jurisdiction of the HLURB Regional Field Office and participating in the proceedings, respondents cannot belatedly reject or repudiate that jurisdiction. Their active participation, coupled with their failure to object, is tantamount to an invocation of that jurisdiction and a willingness to abide by the resolution of the case. The Court further found that the HLURB Board of Commissioners has competent jurisdiction to take cognizance of the Verified Petition for Review filed by petitioners, owing to its authority to determine appeals from decisions of its Regional Offices as provided under Executive Order No. 648 and the HLURB Rules of Procedure. The Court found it unnecessary to address the issues of timeliness and the correct forum for the appeal, as these issues hinged on the determination of whether the HLURB could decide the petition for review, which was already established by the ruling on jurisdiction and estoppel. On the timeliness and finality of the Zoning Administrator's decision, and whether the filing of the petition was an afterthought: The Court found it unnecessary to address the issues of timeliness and the correct forum for the appeal, as these issues hinged on the determination of whether the HLURB could decide the petition for review, which was already established by the ruling on jurisdiction and estoppel. On the alleged violation of the Zoning Ordinance: The Court found that the issue of whether the construction violated the Zoning Ordinance involved a determination of factual matters that should first be settled by the HLURB. This issue was pending resolution by the HLURB Board of Commissioners, and thus, it was beyond the province of the Supreme Court to rule on it at that stage.
Main Doctrine
Parties who actively participate in the proceedings before a quasi-judicial body without raising objections to its jurisdiction are estopped from later impugning its jurisdiction, even if the issue of jurisdiction is raised at the earliest opportunity in the appellate stage.