National Water Resources Board v. Ang Network
REITERATIONFacts
The Antecedents: Respondent, A. L. Ang Network, Inc., applied for a Certificate of Public Convenience (CPC) with the National Water Resources Board (NWRB) to operate a water service system in Alijis, Bacolod City. This application was opposed by the Bacolod City Water District (BACIWA), which asserted its sole authority to operate such a system within the city. Initially, the NWRB granted the CPC, but upon reconsideration, allowed BACIWA to present evidence, leading to the subsequent legal challenge. Procedural History: The NWRB's reconsideration prompted A. L. Ang Network, Inc. to file a petition for certiorari with the Regional Trial Court (RTC) of Bacolod City. The RTC dismissed the petition, ruling that it lacked jurisdiction and that the proper recourse was to the Court of Appeals, citing Rule 43 of the Rules of Court. However, the Court of Appeals, in its decision, annulled and set aside the RTC's order, holding that the RTC did possess jurisdiction over appeals from NWRB decisions, referencing prior Supreme Court rulings. The NWRB's motion for reconsideration was denied, leading to the present petition before the Supreme Court. The Petition: The NWRB filed a petition for review, arguing that the RTC has no certiorari jurisdiction over its decisions because Article 89 of Presidential Decree No. 1067 (PD 1067), which allowed appeals to the RTC, has been superseded and repealed by Batas Pambansa Bilang 129 (BP 129) and the Rules of Court. The NWRB contends that BP 129 and Rule 43 of the Rules of Court vest exclusive appellate jurisdiction over quasi-judicial agencies in the Court of Appeals, and that PD 1067 does not grant the RTC certiorari jurisdiction over the NWRB. The NWRB maintains that appeals and certiorari petitions concerning its adjudications should be filed with the Court of Appeals.
Issue(s)
Whether the Regional Trial Courts have jurisdiction over appeals from decisions, resolutions, or orders of the National Water Resources Board. Whether Article 89 of Presidential Decree No. 1067 (Water Code of the Philippines) has been repealed or superseded by Batas Pambansa Blg. 129 (Judiciary Reorganization Act of 1980) and the Rules of Court.
Ruling
The Supreme Court reversed and set aside the decision and resolution of the Court of Appeals, and upheld the April 15, 2005 Order of the Regional Trial Court of Bacolod City dismissing the petition for lack of jurisdiction.
Ratio Decidendi
On the jurisdiction of Regional Trial Courts over appeals from decisions of the National Water Resources Board: The Supreme Court held that the Regional Trial Court (RTC) does not have jurisdiction over petitions for certiorari and prohibition to annul or modify the acts or omissions of the National Water Resources Board (NWRB) as a quasi-judicial agency. Citing Section 4 of Rule 65 of the Rules of Court, petitioner contended that there is no law or rule requiring the filing of a petition for certiorari over its acts or omissions in any court other than the Court of Appeals (CA). The Court clarified that while Section 9(1) of BP 129 granted the CA original jurisdiction to issue writs of mandamus, prohibition, certiorari, habeas corpus, and quo warranto, and Section 43 of the Rules of Court grants the CA exclusive appellate jurisdiction over quasi-judicial agencies, petitions for certiorari against such agencies should be filed with the CA. The Court found the CA's construction that Article 89 of PD 1067 is an exception to be erroneous. On the repeal of Article 89 of PD 1067 by BP 129: The Supreme Court ruled that Article 89 of PD 1067 had long been rendered inoperative by the passage of BP 129. Section 47 of BP 129 repealed or modified provisions of law inconsistent with its provisions. The Court reasoned that in enacting BP 129, the Batasang Pambansa was presumed to have knowledge of Article 89 of PD 1067 and intended to change it, as the legislative intent to repeal Article 89 is clear and manifest given the scope and purpose of BP 129, which is to provide a homogeneous procedure for the review of adjudications of quasi-judicial entities to the Court of Appeals. The Court emphasized that what Article 89 conferred to the RTC was the power of review on appeal, not certiorari jurisdiction, and that the ground of 'grave abuse of discretion' mentioned in Article 89 was merely another ground for an ordinary appeal to the RTC, not a basis for certiorari jurisdiction. The issuance of BP 129 and the subsequent formulation of the Rules clarified and delineated the appellate and certiorari jurisdictions of the CA over adjudications of quasi-judicial bodies, where grave abuse of discretion may be invoked as a ground for an error of jurisdiction before the appellate court.
Main Doctrine
The Regional Trial Court has jurisdiction over appeals from decisions of the National Water Resources Board, as Article 89 of PD 1067, which grants such appellate jurisdiction, has not been repealed by BP 129.