G.R. No. 178347 ; February 25, 2013
SALVACION VILLANUEVA, et al., Petitioners, vs. PALAWAN COUNCIL FOR SUSTAINABLE DEVELOPMENT (PCSD) and PATRICIA LOUISE MINING AND DEVELOPMENT CORPORATION, Respondents.

FACTS

The Palawan Council for Sustainable Development (PCSD) issued a Strategic Environment Plan (SEP) Clearance to Patricia Louise Mining and Development Corporation (PLMDC) for a small-scale nickel mining project in Narra, Palawan. Petitioners, farmers and residents of the affected barangay, sought the recall of this clearance, arguing the project violated provisions of R.A. No. 7611 (the SEP Law) and PCSD resolutions, as the site was allegedly a protected core zone, not a controlled use area. The PCSD denied their request. Petitioners subsequently filed a Petition for Certiorari and Mandamus with the Regional Trial Court (RTC) to nullify the clearance. The RTC initially ruled it had jurisdiction, finding PCSD exercised quasi-judicial functions. Upon reconsideration, however, the RTC dismissed the petition for lack of jurisdiction, holding that under Rule 65, only the Court of Appeals can review acts of a quasi-judicial body.

ISSUE

Whether the Regional Trial Court correctly dismissed the Petition for Certiorari for lack of jurisdiction.

RULING

The Supreme Court affirmed the RTC’s dismissal, but on a different legal ground. The Court held that a writ of certiorari under Rule 65 lies only against a tribunal, board, or officer exercising judicial or quasi-judicial functions. The Court found that the PCSD was not exercising a quasi-judicial function when it issued the SEP Clearance. Quasi-judicial power requires an enabling statute conferring the authority to adjudicate rights, following a procedure with essential judicial attributes like the power to receive evidence, determine facts, and render binding judgments. R.A. No. 7611 , which created the PCSD, enumerates its powers and functions as planning, policy-making, and coordinative; it does not grant adjudicatory authority. The SEP Clearance process under PCSD Administrative Order No. 6, involving document review and public hearings, is merely an evaluative and administrative preliminary step in the regulatory process. It does not involve the determination of legal rights between contending parties in a manner that is conclusive and binding. Since the act complained of was not performed in a quasi-judicial capacity, the special civil action for certiorari was an improper remedy. Consequently, the RTC did not acquire jurisdiction over the petition. The proper recourse for petitioners was an ordinary civil action for declaratory relief or to question the clearance in an appropriate administrative forum, not a petition for certiorari.