G.R. No. 199199 ; August 27, 2013
MARICRIS D. DOLOT, CHAIRMAN OF THE BAGONG ALYANSANG MAKABAYAN-SORSOGON, PETITIONER vs. HON. RAMON PAJE, IN HIS CAPACITY AS THE SECRETARY OF THE DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES, ET AL., RESPONDENTS.

FACTS

Petitioner Maricris D. Dolot, representing an alliance, filed a petition for Continuing Mandamus, Damages, and Attorney’s Fees with a prayer for a Temporary Environment Protection Order (TEPO) before the Regional Trial Court (RTC) of Sorsogon, Branch 53. The petition sought to halt alleged illegal small-scale iron ore mining operations in Matnog, Sorsogon, contending the operations lacked proper permits, violated environmental laws, and posed grave ecological hazards to the geologically vulnerable municipality. The petitioners impleaded various national and local government officials and the mining operators.
The RTC, Branch 53, summarily dismissed the case for lack of jurisdiction. It reasoned that under Supreme Court Administrative Circular No. 23-2008, which designates specific environmental courts, its territorial jurisdiction was limited to Sorsogon City and five other municipalities, excluding Matnog. The RTC also cited procedural grounds for dismissal, including the absence of a prior final court order for the mandamus to enforce, failure to exhaust administrative remedies, and non-compliance with the requirement to furnish copies to the government.

ISSUE

The primary issue is whether the RTC, Branch 53, correctly dismissed the petition for lack of jurisdiction. The secondary issues are whether the petition was dismissible on the procedural grounds cited by the trial court.

RULING

The Supreme Court reversed the RTC’s dismissal. On jurisdiction, the Court held the RTC committed a fundamental error. Jurisdiction is conferred by law, specifically Batas Pambansa Blg. 129, which grants RTCs original jurisdiction over special civil actions like mandamus, enforceable throughout their judicial region. Administrative Circular No. 23-2008 merely designates venue for environmental cases; it does not and cannot diminish the statutory jurisdiction of an RTC. Branch 53, as an RTC, inherently possessed jurisdiction over the petition for continuing mandamus. Its erroneous reliance on the circular to decline jurisdiction was a grave abuse of discretion.
Regarding the procedural grounds, the Supreme Court found them unmeritorious. A petition for a writ of continuing mandamus under the Rules of Procedure for Environmental Cases does not require a prior final court order; it is precisely the remedy to compel agency action on environmental laws. The doctrine of exhaustion of administrative remedies is not an ironclad rule and admits exceptions, such as when the issue is purely legal, as in this case involving the interpretation of jurisdictional boundaries. While the petitioners may have committed procedural lapses, these did not justify the outright dismissal on jurisdictional grounds. The case was remanded to the RTC for proper proceedings on the merits.