National Water Resources Board v. Ang Network
ABANDONMENTFacts
The Antecedents: Respondent A.L. Ang Network, Inc. filed an application for a Certificate of Public Convenience (CPC) with petitioner National Water Resources Board (NWRB) to operate a water service system. The Bacolod City Water District (BACIWA) opposed this application, asserting its sole authority to operate such a system within the city. Initially, the NWRB granted the CPC, but upon BACIWA's motion for reconsideration alleging a violation of due process for not being allowed to present evidence, the NWRB reconsidered and allowed BACIWA to present its evidence. Procedural History: Following the NWRB's reconsideration, A.L. Ang Network filed a petition for certiorari with the Regional Trial Court (RTC) of Bacolod City against the NWRB and BACIWA. The NWRB moved to dismiss, arguing that the proper recourse was to the Court of Appeals under Rule 43 of the Rules of Court. The RTC dismissed the petition, holding that it lacked jurisdiction as the Court of Appeals has exclusive appellate jurisdiction over decisions of quasi-judicial agencies, citing the repeal of Article 89 of P.D. 1067 by B.P. 129. A.L. Ang Network then filed a petition for certiorari with the Court of Appeals, which annulled the RTC's order, ruling that the RTC did have jurisdiction, citing previous Supreme Court decisions and Article 89 of P.D. 1067 as an exception to the general rule. The Petition: The NWRB filed the present petition for review, contending that the RTC lacks certiorari jurisdiction over the NWRB because Article 89 of P.D. 1067 regarding appeals has been superseded by B.P. 129 and the Rules of Court. The NWRB argues that B.P. 129 and Rule 65 of the Rules of Court vest exclusive certiorari jurisdiction over quasi-judicial agencies in the Court of Appeals, and that Article 89 of P.D. 1067 does not grant the RTC certiorari jurisdiction. The NWRB asserts that B.P. 129 implicitly repealed Article 89 of P.D. 1067, establishing a uniform procedure for reviewing quasi-judicial decisions through the Court of Appeals.
Issue(s)
Whether Regional Trial Courts have jurisdiction over petitions for certiorari assailing decisions, resolutions, or orders of the National Water Resources Board (NWRB) as a quasi-judicial agency.
Ruling
The petition is granted. The challenged Decision and Resolution of the Court of Appeals are reversed and set aside. The April 15, 2005 Order of the Regional Trial Court of Bacolod City dismissing the petition for lack of jurisdiction is upheld. No costs.
Ratio Decidendi
On the Issue of Jurisdiction: The Supreme Court held that Regional Trial Courts (RTCs) lack jurisdiction over appeals or petitions for certiorari from NWRB decisions, as such jurisdiction exclusively pertains to the Court of Appeals (CA) under BP 129 and Rules 43 and 65 of the Rules of Court. Section 9(1) of BP 129 grants the CA original jurisdiction over writs of certiorari, prohibition, and mandamus, while Section 9(3) provides exclusive appellate jurisdiction over quasi-judicial agencies; Rule 43, Section 1 extends this to NWRB despite its non-enumeration, as the list is illustrative per precedents like United Coconut Planters Bank v. E. Ganzon. Rule 65, Section 4 mandates filing certiorari petitions against quasi-judicial agencies with the CA 'unless otherwise provided by law or these rules,' and no such exception exists for PD 1067. Article 89 of PD 1067, conferring RTC appellate review on grounds of grave abuse of discretion, questions of law, or fact and law, was rendered inoperative by BP 129's Section 47, a general repealing clause abrogating inconsistent prior laws, as the Batasang Pambansa presumed knowledge of PD 1067 and intended uniform procedure via CA review. The CA erred in treating 'grave abuse of discretion' under Article 89 as conferring certiorari jurisdiction on RTCs; it was merely a ground for ordinary appeal, now supplanted by CA's power to review jurisdictional errors. Prior cases like BF Northwest (1987) are no longer controlling post-Rule 43, and Tanjay Water District addressed original jurisdiction between NWRB predecessor and RTC, not appellate review. This ensures procedural homogeneity, with respondent's certiorari invoking grave abuse as excess of jurisdiction properly belonging to CA.
Main Doctrine
Article 89 of PD 1067, which purportedly grants Regional Trial Courts (RTCs) appellate jurisdiction over decisions of the National Water Resources Board (NWRB) on grounds including grave abuse of discretion, questions of law, and questions of fact and law, has been rendered inoperative by the enactment of BP 129, particularly through its general repealing clause in Section 47 that abrogates inconsistent prior statutes. BP 129 vests the Court of Appeals with exclusive appellate jurisdiction over final judgments, orders, resolutions, or awards of quasi-judicial agencies under Section 9(3), and original jurisdiction over writs of certiorari, prohibition, and mandamus under Section 9(1), reinforced by Rule 43 and Rule 65, Section 4 of the Rules of Court. The phrase 'unless otherwise provided by law or these rules' in Rule 65, Section 4 admits no exception for PD 1067, as the legislative intent of BP 129 was to establish procedural uniformity in reviewing quasi-judicial adjudications by directing all such appeals and certiorari petitions to the Court of Appeals. Prior cases like BF Northwest Homeowners Association v. Intermediate Appellate Court are no longer controlling, as Rule 43's definitive instruction supersedes them. Thus, certiorari jurisdiction over NWRB acts or omissions, especially invoking grave abuse of discretion as lack or excess of jurisdiction, belongs exclusively to the Court of Appeals, distinguishing it from ordinary appeals or errors of judgment.