G.R. No. L-72370 May 29, 1987
BF NORTHWEST HOMEOWNERS ASSOCIATION, INC., petitioner, vs. INTERMEDIATE APPELLATE COURT and BF HOMES, INC., respondents.

FACTS

The National Water Resources Council (NWRC) granted BF Homes, Inc. a Certificate of Public Convenence and approved a Compromise Agreement on water rates. The NWRC later issued orders increasing these rates. Petitioner BF Northwest Homeowners Association, Inc. filed an ordinary civil suit (Civil Case No. 7584) in the Regional Trial Court (RTC) seeking to annul these NWRC issuances, arguing they were rendered without due process and with grave abuse of discretion. The RTC dismissed the case for lack of jurisdiction. The Intermediate Appellate Court affirmed the dismissal, ruling that the NWRC, having taken over the functions of the former Public Service Commission, stood on equal footing with the RTC. Therefore, its decisions could only be reviewed by the Court of Appeals via a petition for review under its appellate jurisdiction, not collaterally attacked in an ordinary civil action before the RTC. The Appellate Court also cited res judicata, as a prior case had already resolved the jurisdictional issue.

ISSUE

Whether the Regional Trial Court has jurisdiction over an ordinary civil action seeking to annul the orders and resolutions of the National Water Resources Council.

RULING

No, the Regional Trial Court does not have jurisdiction. The Supreme Court set aside the Appellate Court’s decision but on different grounds, ultimately affirming the dismissal. The legal logic is that the NWRC is a quasi-judicial agency. Pursuant to Batas Pambansa Blg. 129, the Court of Appeals exercises exclusive appellate jurisdiction over final orders of such agencies. A party aggrieved by an NWRC order cannot circumvent this appellate review process by filing an original action for annulment in the RTC. The proper remedy is a petition for review filed directly with the Court of Appeals. The Supreme Court clarified that the NWRC is not “on equal footing” with the RTC in terms of rank or stature, but its orders are not subject to collateral attack in an ordinary civil case in the RTC. The doctrine of hierarchy of courts dictates that the specific statutory mode of appeal must be followed. However, in the interest of justice, the Supreme Court remanded the case to the RTC but with the crucial instruction that it be treated as a petition for review and certified to the Court of Appeals. The ruling emphasizes that quasi-judicial agency decisions must be challenged through the prescribed appellate channels, not through original actions in trial courts.