G.R. No. 218056 , August 31, 2022
Republic of the Philippines, represented by the Privatization and Management Office, Petitioner, vs. City of Surigao, as represented by City Mayor Ernesto T. Matugas and City Treasurer Sarah P. Yamit, Respondents.

FACTS

The Privatization and Management Office (PMO), as successor to the Asset Privatization Trust, held certain redundant assets in Surigao City. The City Assessor initially declared these assets exempt from real property tax. However, in 2011, the City Government demanded payment of over PHP 200 million in alleged delinquent real property taxes and levied the properties. The PMO protested, asserting the assets were government-owned and thus tax-exempt. The City proceeded to schedule a public auction.
The PMO filed a Petition for Prohibition with an application for a Temporary Restraining Order (TRO) and/or Writ of Preliminary Injunction before the Regional Trial Court (RTC) of Surigao City. The RTC denied the application for a preliminary injunction, allowing the auction to proceed subject to proper procedures. The PMO filed a motion for reconsideration but subsequently withdrew it to file a petition for certiorari under Rule 65 directly with the Court of Appeals (CA), arguing the RTC committed grave abuse of discretion. The CA denied the petition on technical grounds, citing failure to exhaust administrative remedies and to file a motion for reconsideration of the RTC’s order.

ISSUE

Whether the Court of Appeals correctly dismissed the petition for certiorari on procedural grounds.

RULING

No. The Supreme Court reversed the CA and clarified the proper appellate jurisdiction. The core legal logic hinges on the exclusive appellate jurisdiction of the Court of Tax Appeals (CTA) over local tax cases. Under Republic Act No. 9282 , the CTA has exclusive appellate jurisdiction to review decisions, orders, or resolutions of the RTC in local tax cases originally decided by them. A petition for prohibition questioning a local government unit’s tax collection, which was filed with and resolved by the RTC, is a local tax case falling within this jurisdiction.
Consequently, the PMO’s recourse from the RTC’s denial of injunctive relief was not a Rule 65 petition to the CA, but an appeal to the CTA. Since the CTA has exclusive appellate jurisdiction, it inherently possesses the ancillary power to issue writs of certiorari in aid of that jurisdiction. Therefore, the CA had no jurisdiction to entertain the petition. The PMO’s procedural misstep in filing with the CA was a jurisdictional error, not merely a technical lapse warranting dismissal. The Supreme Court thus remanded the case to the CTA for proper disposition, emphasizing that the CTA’s jurisdiction is paramount in tax matters to ensure expertise and uniformity. The ruling reinforces that the hierarchy of judicial review in local tax controversies is from the RTC directly to the CTA, not to the CA.