Jurisdiction over annulment of environmental compliance certificate

"xxx.

Jurisdiction of the Manila RTC over the Case

Jurisdiction over the subject matter of a case is conferred by law. Such jurisdiction is determined by the allegations in the complaint, irrespective of whether the plaintiff is entitled to all or some of the reliefs sought.11

A perusal of the allegations in the complaint shows that petitioners' principal cause of action is the alleged illegality of the issuance of the ECC. The violation of laws on environmental protection and on local government participation in the implementation of environmentally critical projects is an issue that involves the validity of NAPOCOR's ECC. If the ECC is void, then as a necessary consequence, NAPOCOR or the provincial government of Oriental Mindoro could not construct the mooring facility. The subsidiary issue of non-compliance with pertinent local ordinances in the construction of the mooring facility becomes immaterial for purposes of granting petitioners' main prayer, which is the annulment of the ECC. Thus, if the court has jurisdiction to determine the validity of the issuance of the ECC, then it has jurisdiction to hear and decide petitioners' complaint.

Petitioners' complaint is one that is not capable of pecuniary estimation. It falls within the exclusive and original jurisdiction of the Regional Trial Courts under Section 19(1) of Batas Pambansa Blg. 129, as amended by Republic Act No. 7691. The question of whether petitioners should file their complaint in the Regional Trial Court of Manila or Oriental Mindoro then becomes a matter of venue, to be determined by the residence of the parties.12

Petitioners' main prayer is the annulment of the ECC. The principal respondent, DENR Region IV, has its main office at the L & S Building, Roxas Boulevard, Manila. Regional Executive Director Principe of the DENR Region IV, who issued the ECC, holds office there. Plainly, the principal respondent resides in Manila, which is within the territorial jurisdiction of the Manila RTC. Thus, petitioners filed their complaint in the proper venue.

On the other hand, the jurisdiction of Regional Trial Courts to issue injunctive writs is limited to acts committed or about to be committed within their judicial region.13 Moreover, Presidential Decree No. 1818 ("PD No. 1818") prohibited14 courts from issuing injunctive writs against government infrastructure projects like the mooring facility in the present case. Republic Act No. 8975 ("RA No. 8975"), which took effect on 26 November 2000, superseded PD No. 1818 and delineates more clearly the coverage of the prohibition, reserves the power to issue such writs exclusively with this Court, and provides penalties for its violation.15 Obviously, neither the Manila RTC nor the Oriental Mindoro RTC can issue an injunctive writ to stop the construction of the mooring facility. Only this Court can do so under PD No. 1818 and later under RA No. 8975. Thus, the question of whether the Manila RTC has jurisdiction over the complaint considering that its injunctive writ is not enforceable in Oriental Mindoro is academic.

Clearly, the Manila RTC has jurisdiction to determine the validity of the issuance of the ECC, although it could not issue an injunctive writ against the DENR or NAPOCOR. However, since the construction of the mooring facility could not proceed without a valid ECC, the validity of the ECC remains the determinative issue in resolving petitioners' complaint.

Xxx."


FIRST DIVISION
G.R. No. 131442, July 10, 2003

BANGUS FRY FISHERFOLK, DIWATA MAGBUHOS, ANGELITA BINAY, ELMA GARCIA, VIRGILIO PANGUIO, ARSENIO CASTILLO, ARIEL PANGUIO, ANTONIO PANGUIO, ANTONIO BUNQUIN, GENEROSO BUNQUIN, CHARLIE DIMAYACYAC, RENATO PANGUIO, ATILANO BUNQUIN, CARLOS CHAVEZ, JUAN DIMAYACYAC, FILEMON BUNQUIN, MARIO MAGBUHOS, MAURO MAGBUHOS, NORA MAGBUHOS, JEOVILYN, GENALYN and JORVAN QUIMUEL, minors, represented by their parents FELICIANA and SABINO QUIMUEL, MARICAR MAGBUHOS, minor, represented by her parents CARMELITA and ANTONIO MAGBUHOS, MARLO BINAY, minor, represented by his parents EFRENITA and CHARLITO BINAY, and the BANGUS, BANGUS FRY and other MARINE LIFE OF MINOLO COVE, petitioners,
vs.
THE HONORABLE ENRICO LANZANAS as Judge of the Regional Trial Court of Manila, Branch VII, THE DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES — Region IV, represented by its Regional Executive Director and its Regional Director for Environment, THE NATIONAL POWER CORPORATION, ORIENTAL MINDORO ELECTRIC COOPERATIVE, PROVINCIAL GOVERNMENT OF ORIENTAL MINDORO, herein represented by GOVERNOR RODOLFO VALENCIA, PUERTO GALERA MAYOR GREGORIO DELGADO, VICE MAYOR ARISTEO ATIENZA, and MEMBERS OF THE SANGGUNIANG BAYAN OF PUERTO GALERA, JUAN ASCAN, JR., RAFAEL ROMEY, CENON SALCEDO, JERRY DALISAY, SIMON BALITAAN, RENATO CATAQUIS, MARCELINO BANAAG, DANIEL ENRIQUEZ, AMELYN MARCO, GABRIEL ILAGAN, MUNICIPAL ENGINEER RODEL RUBIO, and MUNICIPAL PLANNING and DEVELOPMENT COORDINATOR WILHELMINA LINESES, respondents.

https://lawphil.net/judjuris/juri2003/jul2003/gr_131442_2003.html