GR 175039; (April, 2012) (Digest)
G.R. No. 175039 ; April 18, 2012
Addition Hills Mandaluyong Civic & Social Organization, Inc. vs. Megaworld Properties & Holdings, Inc., Wilfredo I. Imperial, in his capacity as Director, NCR, and Housing and Land Use Regulatory Board, Department of Natural Resources
FACTS
Megaworld Properties & Holdings, Inc. owned a parcel of land in Mandaluyong City and secured the necessary permits, including a Certificate of Locational Viability (CLV) and a Development Permit from the Housing and Land Use Regulatory Board (HLURB), to construct the Wack-Wack Heights Condominium. The Addition Hills Mandaluyong Civic & Social Organization, Inc. (AHMCSO), a neighboring homeowners’ association, filed a complaint before the Regional Trial Court (RTC) of Pasig City seeking to annul these permits. AHMCSO alleged the project violated zoning ordinances and would deprive adjacent properties of light and air.
Megaworld moved to dismiss the case, arguing the RTC lacked jurisdiction as the HLURB had primary jurisdiction over disputes concerning the issuance of such permits. The RTC denied the motion, proceeded with the trial, and eventually ruled in favor of AHMCSO, declaring the permits void. Megaworld appealed to the Court of Appeals.
ISSUE
Whether the Court of Appeals correctly reversed the RTC’s decision on the ground that AHMCSO failed to exhaust administrative remedies by not first seeking relief from the HLURB before filing a judicial action.
RULING
Yes, the Court of Appeals was correct. The Supreme Court affirmed the dismissal of the complaint for failure to exhaust administrative remedies. The legal logic is anchored on the doctrine of primary jurisdiction, which holds that courts cannot or will not determine a controversy involving a question within the jurisdiction of an administrative tribunal, especially when the issue demands technical expertise. The issuance of a CLV and a Development Permit by the HLURB involves the exercise of administrative discretion and technical knowledge on zoning and land use.
The HLURB, under its charter and rules, has the explicit authority to hear and decide cases regarding the issuance, revocation, and annulment of such permits. An opposition to an application for these permits is, in fact, considered a contested case within the HLURB’s jurisdiction. AHMCSO’s proper course was to file an opposition or an administrative case with the HLURB to question the validity of the permits. By directly resorting to the RTC without first availing of this plain, speedy, and adequate administrative remedy, AHMCSO’s action was premature. The Court found no compelling reason to apply any exception to the exhaustion rule, as the questions involved were not purely legal and required the HLURB’s specialized competence. Consequently, the RTC should have dismissed the case for lack of jurisdiction.