G.R. No. L-42380 June 22, 1990
DATILES AND COMPANY, represented by LORETA DATILES and LARRY DATILES, petitioner, vs. Honorable MELQUIADES S. SUCALDITO, Presiding Judge of Branch I, Court of First Instance of Zamboanga del Sur, Honorable MATIAS A. GUIEB, or his Successor-in-Office, Regional Director, Region No. IX, Bureau of Fisheries and Aquatic Resources and JESUS DEYPALUBOS and DANIEL CABELIEZA, respondents.

FACTS

Petitioner Datiles and Company held a Fishpond Lease Agreement (FLA) for a 175-hectare area in Zamboanga del Sur. In 1973, it filed a civil case for injunction (Civil Case No. 1389) against private respondents Jesus Deypalubos and Daniel Cabelieza, who had occupied portions of the leased area and filed their own lease applications. The trial court issued a writ of preliminary mandatory injunction, restoring possession to the petitioner. Meanwhile, Deypalubos filed a formal protest with the Bureau of Fisheries and Aquatic Resources (BFAR) against the petitioner’s lease, and a Barrio Council submitted a resolution supporting Deypalubos and questioning the grant’s size.
The BFAR Director initially ordered a hold on investigating the protest and resolution pending the civil case’s resolution. However, in a subsequent memorandum dated January 3, 1975, the Director directed public respondent Regional Director Matias Guieb to conduct an immediate formal investigation of issues in the protest and resolution “not touched upon in Civil Case No. 1389.” Petitioner then filed a petition for prohibition/injunction (Special Civil Case No. 1426) before the Court of First Instance to restrain the investigation, arguing the issues were the same as those in the pending civil case. The trial court initially issued a restraining order.

ISSUE

Whether the Regional Trial Court had jurisdiction to entertain the petition for prohibition/injunction to restrain the BFAR Regional Director’s investigation of the protest, considering the doctrine of exhaustion of administrative remedies and the jurisdictional bar under Presidential Decree No. 605.

RULING

No, the Regional Trial Court had no jurisdiction. The Supreme Court reversed the Court of Appeals and reinstated the trial court’s dismissal of the petition for prohibition. The legal logic is twofold. First, the petitioner failed to exhaust administrative remedies. The investigation by the BFAR Regional Director was a preliminary step in an administrative process concerning a fishpond lease grant, a matter squarely within the BFAR’s primary jurisdiction. Judicial interference through prohibition was premature, as the administrative agency should be allowed to complete its proceedings and render a decision, which could then be appealed through the proper administrative and judicial hierarchy.
Second, and decisively, Presidential Decree No. 605 expressly divests courts of jurisdiction to issue restraining orders or injunctions in any case involving actions by administrative officials on licenses, permits, or public grants concerning the development of natural resources. The BFAR Director’s order for an investigation into the protest against the fishpond lease agreement is unequivocally an “action” on a permit or public grant involving a natural resource (fisheries). Therefore, under the clear mandate of P.D. 605, the trial court was devoid of jurisdiction to issue the restraining order or to entertain the petition for prohibition. The proper course was to allow the administrative investigation to proceed.