G.R. No. 202781, January 10, 2017
Crisanto M. Aala, et al. vs. Hon. Rey T. Uy, in his capacity as the City Mayor of Tagum City, et al.

FACTS

Petitioners, residents and taxpayers of Tagum City, filed an original action for Certiorari, Prohibition, and Mandamus directly with the Supreme Court. They sought to nullify City Ordinance No. 558, s-2012, which adopted a new schedule of market values and assessment levels for real properties in the city. Their petition alleged that the ordinance violated specific provisions of the Local Government Code by classifying and valuing properties based on their location within zoned areas rather than their actual use, and by imposing allegedly exorbitant taxes.
Prior to this Court action, the Sangguniang Panlalawigan of Davao del Norte, in the exercise of its review power, had issued Resolution No. 428 declaring several sections of the ordinance invalid. However, the Sangguniang Panlungsod of Tagum City subsequently passed Resolution No. 874, s-2012, asserting the ordinance’s validity. The city council argued that the provincial board’s inaction for 30 days after receipt of the ordinance gave rise to a presumption of validity under the Local Government Code. The ordinance was then published.

ISSUE

Whether the petitioners’ direct recourse to the Supreme Court via an original action for Certiorari, Prohibition, and Mandamus is proper, considering the doctrines of hierarchy of courts and exhaustion of administrative remedies.

RULING

No. The Supreme Court dismissed the petition for being procedurally infirm. The Court emphasized the strict application of the doctrine of hierarchy of courts, which mandates that a petition should first be filed with the appropriate lower court unless exceptional circumstances justify direct filing with the Supreme Court. No such compelling reasons were present here. More critically, the petitioners failed to exhaust available administrative remedies. The Local Government Code provides a specific protest mechanism under Section 195, where a taxpayer may contest an assessment by filing a written protest with the local treasurer. This administrative recourse is a condition precedent for judicial action. Furthermore, questions on the validity of a tax ordinance are primarily within the jurisdiction of the Regional Trial Court, not the Supreme Court, in a petition for declaratory relief. By bypassing these established procedures, the petitioners brought a premature case, which contributes to the overclogging of the Court’s dockets. The dismissal is without prejudice to the petitioners availing of the correct administrative and judicial pathways.