G.R. No. 253821 . March 06, 2023.
SUGAR REGULATORY ADMINISTRATION, PETITIONER, VS. CENTRAL AZUCARERA DE BAIS INC., RESPONDENT.

FACTS

The Sugar Regulatory Administration (SRA) issued Sugar Order Nos. 1, 1-A, and 3, Series of 2017-2018, allocating Class “D” world market sugar to accredited Class “F” ethanol producers. Central Azucarera De Bais, Inc. filed a Petition for Declaratory Relief before the Regional Trial Court (RTC) of Makati, questioning the legality of the SRA’s Orders as ultra vires. The SRA defended the Orders, claimed Central Azucarera lacked legal standing, and argued the case was moot due to the subsequent issuance of Sugar Order No. 1-B, which removed the contested allocation. The parties agreed during proceedings that the case involved no factual issues. Central Azucarera moved for summary judgment. The RTC granted the motion and declared the Sugar Orders null and void, ruling that ethanol producers are not part of the sugar industry and fall under the regulatory jurisdiction of the Department of Energy, not the SRA. The SRA appealed this decision to the Court of Appeals (CA). Central Azucarera moved to dismiss the appeal, arguing it raised only questions of law, making a direct petition for review on certiorari to the Supreme Court the proper remedy. The CA granted the motion and dismissed the SRA’s appeal for being an improper remedy. The SRA’s motion for reconsideration was denied.

ISSUE

Whether the Court of Appeals correctly dismissed the SRA’s appeal on the ground that it raised only pure questions of law, making an appeal to the CA under Rules 41 and 44 of the Rules of Court an improper remedy.

RULING

Yes, the Court of Appeals correctly dismissed the appeal. The Petition for Declaratory Relief filed by Central Azucarera inherently involved only the construction or validity of the SRA’s Sugar Orders—a pure question of law. The core issue was whether the SRA had the legal authority to allocate sugar to ethanol producers, which required an interpretation of its statutory mandate and did not necessitate an examination of the probative value of evidence. The SRA’s arguments on appeal concerning Central Azucarera’s legal standing and the mootness of the case were also questions of law, as their resolution depended on the application of legal principles to established or undisputed facts. Under the Rules of Court, an appeal from an RTC decision involving only questions of law must be brought directly to the Supreme Court via a petition for review on certiorari under Rule 45. An appeal on pure questions of law erroneously taken to the CA is subject to outright dismissal under Rule 50, Section 2 of the Rules of Court. Therefore, the SRA availed of the wrong mode of appeal, and the CA’s dismissal was proper. The Supreme Court denied the SRA’s Petition for Review on Certiorari for lack of merit.