Rodriguez v. Housing and Land Use Regulatory Board
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the Spouses Jose and Corazon Rodriguez's acquisition and subsequent attempt to consolidate and develop a road lot within the Ruben San Gabriel Subdivision. Complainants, including residents and other lot owners in the subdivision, alleged that the Spouses Rodriguez unlawfully claimed ownership of the road lot, which serves as a crucial access to MacArthur Highway for inner lots. They asserted that this road lot, being part of the subdivision's open spaces, could not be closed or conveyed without court approval and was intended for public use, as per Republic Act No. 440 and PD 957. The Spouses Rodriguez, however, had acquired several lots from the original owner and another buyer, and subsequently obtained an approval for an Alteration of Plan that consolidated their titles, including the subject road lot, into a single Transfer Certificate of Title. 2. Procedural History: Initially, complaints were filed by Spouses Balbino and Spouses Nicolas, and later by Spouses Santiago, Rogano, and Spouses Gamboa, before the Housing and Land Use Regulatory Board (HLURB) Regional Field Office III (RFO III). These complaints were consolidated, and the HLURB-RFO III issued a Consolidated Decision on October 3, 2005, ordering the Spouses Rodriguez to cease and desist from consolidating the road lot and making the cease and desist order permanent. The Spouses Rodriguez appealed to the HLURB Board of Commissioners, which initially overturned the RFO III's decision but later reinstated it upon reconsideration, holding that the road lot could not be appropriated or closed without a valid alteration permit for its conversion. The Spouses Rodriguez then filed a Petition for Certiorari, Prohibition, and Mandamus under Rule 65 before the Court of Appeals (CA) without first appealing to the Office of the President. The CA dismissed this petition outright for failure to exhaust administrative remedies and for procedural deficiencies. 3. The Petition: In G.R. No. 183324, the Spouses Rodriguez filed a Petition for Review on Certiorari under Rule 45, assailing the CA's dismissal of their Rule 65 petition. They argued that the CA erred in dismissing their petition and, in essence, contended that the HLURB lacked jurisdiction over the subject road lot as it was private titled land. In G.R. No. 209748, Spouses Dr. Amelito S. Nicolas and Edna B. Nicolas filed a Petition for Indirect Contempt against the Spouses Rodriguez and Edjie Manlulu, alleging defiance of the HLURB's cease and desist order by dumping filling materials to block the road lot. The Supreme Court consolidated these two petitions.
Issue(s)
Whether the CA erred in dismissing the Spouses Rodriguez' Rule 65 Petition for failure to exhaust administrative remedies. Whether the Petition for Indirect Contempt filed by the Spouses Nicolas is meritorious.
Ruling
The Court denied the appeal in G.R. No. 183324, affirming the CA's Resolutions dated January 7, 2008, and May 6, 2008. The Court dismissed the Petition for Indirect Contempt in G.R. No. No. 209748.
Ratio Decidendi
On the dismissal of the Rule 65 Petition (G.R. No. 183324): The Court held that the CA did not err in dismissing the Spouses Rodriguez' petition for certiorari. A writ of certiorari requires the petitioner to demonstrate that there is no plain, speedy, and adequate remedy in the ordinary course of law. The Spouses Rodriguez failed to appeal the HLURB Board's Resolutions to the Office of the President, which is a mandatory administrative remedy under the HLURB Rules of Procedure. Their failure to provide any justification for this omission rendered their certiorari petition improper. The Court reiterated that certiorari cannot be used as a substitute for a lost appeal. Even if the Court considered their argument regarding HLURB's jurisdiction, the factual findings of the HLURB, which were supported by substantial evidence, indicated that the road lot was never converted into a regular private lot and remained within HLURB's jurisdiction. The fact that Sps. Rodriguez themselves filed a motion before the HLURB regarding the road lot further supported this conclusion. On the Petition for Indirect Contempt (G.R. No. No. 209748): The Court dismissed the petition for indirect contempt. The Sps. Nicolas alleged that Sps. Rodriguez and Manlulu disobeyed the HLURB's cease and desist order. However, Section 12, Rule 71 of the Rules of Court clearly states that for contemptuous acts committed against quasi-judicial bodies like the HLURB, jurisdiction lies with the Regional Trial Court (RTC) of the place where the contemptuous acts were committed, not the Supreme Court. The Rules of Court unambiguously vest this jurisdiction in the RTCs. The Sps. Nicolas' prayer for the Supreme Court to conduct a hearing and receive evidence on the alleged disobedience was also untenable, as the Court is not a trier of facts; such fact-finding is within the province of lower courts.
Main Doctrine
The Court of Appeals did not err in dismissing the Spouses Rodriguez' petition for certiorari for failure to exhaust administrative remedies. Furthermore, the petition for indirect contempt was dismissed for lack of jurisdiction by the Supreme Court, as such cases against quasi-judicial bodies fall under the Regional Trial Court.