GR 122089; (August, 2000) (Digest)
G.R. No. 122089 ; August 23, 2000
MELITON ZABAT and MARYLOU ZABAT, petitioners, vs. THE HONORABLE COURT OF APPEALS, HONORABLE PRESIDING JUDGE, Branch 114, Pasay City, THE NATIONAL HOUSING AUTHORITY and ALEJANDRA & GUILLERMO MAURI, JR., respondents.
FACTS
Petitioners Meliton and Marylou Zabat contested the award of a 60-square-meter lot in an NHA upgrading project to respondents Alejandra and Guillermo Mauri. The Zabat spouses initially occupied the lot, but an NHA census verification in 1981 found their structure was rented out, leading to their classification as absentee structure owners and disqualification from the award. The lot was subsequently awarded to the Mauris. The Zabats appealed to the NHA’s Awards and Arbitration Committee (AAC), which in 1985 reconsidered Marylou Zabat’s status, declaring her a project beneficiary but of a different lot, as the contested lot had already been allocated. The AAC decision became final after their motion for reconsideration was denied. The NHA executed a conditional contract to sell with the Mauris in August 1985.
ISSUE
Whether the petitioners properly availed of judicial action for injunction without first exhausting administrative remedies.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal principle applied is the doctrine of exhaustion of administrative remedies. The Court held that the petitioners’ proper recourse was to appeal the final decision of the NHA’s AAC to the Office of the President, as mandated by Executive Order No. 19, which governs appeals from awards by government corporations. By failing to pursue this available administrative appeal, the petitioners foreclosed their right to later seek judicial relief. The Court emphasized that administrative disputes must achieve finality, and public policy requires that parties adhere to established procedural hierarchies. Consequently, their direct filing of an injunction case in the Regional Trial Court was procedurally infirm. The injunctive remedy they sought was therefore unavailable, as they had not established a clear legal right, having bypassed the requisite administrative process. The award to the Mauris stood valid.