GR 162124; (October, 2007) (Digest)
G.R. No. 162124; October 18, 2007
POLOMOLOK WATER DISTRICT, Petitioner, vs. POLOMOLOK GENERAL CONSUMERS ASSOCIATION, INC., Respondent.
FACTS
Polomolok Water District (PWD), a government-owned corporation, passed Resolution No. 94-023 in October 1994 imposing new and higher water rates. The Polomolok General Consumers Association, Inc. opposed this, initially filing an administrative complaint with the National Water Resources Board (NWRB), which was dismissed as untimely. Subsequently, the Association filed a class suit before the Regional Trial Court (RTC) of Polomolok, seeking the declaration of nullity of the Resolution, alleging it was passed without the required notice and hearing under Presidential Decree No. 198. The RTC issued a writ of preliminary injunction, enjoining PWD from disconnecting the water supply of the Association’s members.
PWD filed a petition for certiorari with the Court of Appeals, contending the RTC committed grave abuse of discretion. PWD argued that the Association failed to exhaust administrative remedies, as jurisdiction over the dispute allegedly lay with the NWRB, whose decisions are appealable to the National Water Resources Council and then the Office of the President. The Court of Appeals dismissed PWD’s petition and affirmed the RTC’s orders, holding the doctrine of exhaustion of administrative remedies inapplicable.
ISSUE
Whether the Regional Trial Court has jurisdiction over the class suit seeking the declaration of nullity of PWD Resolution No. 94-023, or whether the doctrine of exhaustion of administrative remedies applies, vesting primary jurisdiction in the National Water Resources Board.
RULING
The Supreme Court affirmed the Court of Appeals’ decision, ruling that the RTC validly exercised jurisdiction. Jurisdiction is determined by the material allegations in the complaint and the character of the relief sought. The complaint specifically alleged that the Resolution was null and void for non-compliance with statutory requirements of notice, publication, and hearing, and prayed for its declaration as such. The core issue was the validity or legality of the Resolution itself, not the reasonableness of the water rates. An action for the declaration of the nullity of a resolution or contract is inherently incapable of pecuniary estimation. Under Section 19 of Batas Pambansa Blg. 129, the RTC has exclusive original jurisdiction over all civil actions where the subject of the litigation is incapable of pecuniary estimation. Consequently, the doctrine of exhaustion of administrative remedies does not apply, as the question presented is purely judicial—involving the interpretation and application of law to determine the Resolution’s validity—not an administrative matter requiring specialized technical expertise. The petition was denied.