The Supreme Court clarified that the Court of Appeals, not the Regional Trial Court, has both certiorari and appellate jurisdiction over decisions from the National Water Resources Board (NWRB). This ruling effectively overturns previous interpretations suggesting that RTCs had jurisdiction over NWRB decisions, ensuring a uniform procedure for reviewing adjudications of quasi-judicial entities. For individuals or entities contesting NWRB decisions, this means appeals must now be directed to the Court of Appeals.

Navigating Water Rights: Who Decides – RTC or Court of Appeals?

The central issue in National Water Resources Board v. A. L. Ang Network, Inc. revolves around determining the proper court to handle appeals from the decisions of the National Water Resources Board (NWRB). A.L. Ang Network, Inc. applied for a Certificate of Public Convenience (CPC) to operate a water service system, which was initially granted by the NWRB but later reconsidered due to opposition from the Bacolod City Water District (BACIWA). This led A.L. Ang Network to file a petition for certiorari with the Regional Trial Court (RTC) of Bacolod City. The NWRB moved to dismiss the petition, arguing that the proper venue for appeal was the Court of Appeals, setting the stage for a jurisdictional dispute that ultimately reached the Supreme Court.

The RTC dismissed A.L. Ang Network’s petition, citing a lack of jurisdiction. The RTC held that Batas Pambansa Bilang 129 (BP 129), as amended, had removed the RTC’s appellate jurisdiction over decisions from quasi-judicial agencies like the NWRB, vesting it instead with the Court of Appeals. The appellate court, however, reversed the RTC’s decision, asserting that the RTC had jurisdiction over appeals from NWRB decisions. This assertion was based on an interpretation of Article 89 of Presidential Decree No. 1067 (PD 1067), also known as the Water Code of the Philippines, and prior jurisprudence.

The Supreme Court began its analysis by examining the relevant legal framework. Section 9(1) of BP 129 grants the Court of Appeals original jurisdiction to issue writs of mandamus, prohibition, certiorari, habeas corpus, and quo warranto. Further, Rule 43 of the Rules of Court gives the appellate court exclusive appellate jurisdiction over quasi-judicial agencies. The Court emphasized that petitions for writs of certiorari, prohibition, or mandamus against quasi-judicial agencies like the NWRB should be filed with the Court of Appeals, ensuring procedural uniformity unless otherwise specified by law or the Rules.

The appellate court’s reliance on Article 89 of PD 1067 as an exception to the Court of Appeals’ jurisdiction was deemed erroneous by the Supreme Court. Article 89 of PD 1067 states:

ART. 89. The decisions of the [NWRB] on water rights controversies may be appealed to the [RTC] of the province where the subject matter of the controversy is situated within fifteen (15) days from the date the party appealing receives a copy of the decision, on any of the following grounds: (1) grave abuse of discretion; (2) question of law; and (3) questions of fact and law

The Supreme Court clarified that Article 89 of PD 1067 had been rendered inoperative by the passage of BP 129. Section 47 of BP 129 repealed or modified all statutes, letters of instructions, and general orders inconsistent with its provisions. This general repealing clause indicates that any conflicting provisions in prior acts would be superseded.

In enacting BP 129, the Batasang Pambansa was presumed to be aware of Article 89 of PD 1067 and intended to change it. The legislative intent to repeal Article 89 is clear, considering the scope and purpose of BP 129, which sought to establish a uniform procedure for reviewing adjudications of quasi-judicial entities through the Court of Appeals. The Supreme Court noted that while Article 89 of PD 1067 conferred the power of review on appeal to the RTC, BP 129 shifted this power to the Court of Appeals, clarifying the appellate and certiorari jurisdictions over adjudications of quasi-judicial bodies.

The Supreme Court also addressed the argument that the NWRB was not explicitly listed among the quasi-judicial agencies in Section 9(3) of BP 129 and Section 1 of Rule 43 of the Rules of Court. It clarified that the list of quasi-judicial agencies in Rule 43 is not exhaustive, emphasizing the use of the word “among” as an indication that the list is illustrative rather than restrictive. Therefore, the absence of the NWRB from the list does not preclude the Court of Appeals from exercising appellate jurisdiction over its judgments, orders, resolutions, or awards.

The Supreme Court distinguished the present case from BF Northwest Homeowners Association v. Intermediate Appellate Court, a 1987 case cited by the appellate court. The Court explained that this earlier ruling was no longer controlling due to the definitive instructions of Rule 43 of the Revised Rules of Court. Similarly, the case of Tanjay Water District v. Gabaton was deemed not applicable, as it dealt with the jurisdictional conflict between the RTC and the then National Water Resources Council regarding disputes over water appropriation, utilization, and control.

To summarize, the Supreme Court firmly established that both certiorari and appellate jurisdiction over adjudications of the NWRB properly belong to the Court of Appeals. This decision provides clarity and uniformity in the review process for decisions made by the NWRB, ensuring that appeals are consistently directed to the appropriate appellate court.

FAQs

What was the key issue in this case?	The key issue was determining whether the Regional Trial Court (RTC) or the Court of Appeals has jurisdiction over appeals from decisions of the National Water Resources Board (NWRB).
What did the Supreme Court decide?	The Supreme Court decided that the Court of Appeals, not the RTC, has both certiorari and appellate jurisdiction over decisions from the NWRB.
What is the basis for the Supreme Court’s decision?	The decision is based on the interpretation of Batas Pambansa Bilang 129 (BP 129) and Rule 43 of the Rules of Court, which grant the Court of Appeals exclusive appellate jurisdiction over quasi-judicial agencies.
Did the Supreme Court find that Article 89 of PD 1067 still applies?	No, the Supreme Court found that Article 89 of PD 1067, which granted appellate jurisdiction to the RTC, had been rendered inoperative by the passage of BP 129.
Is the list of quasi-judicial agencies in Rule 43 exhaustive?	No, the Supreme Court clarified that the list of quasi-judicial agencies in Rule 43 is not meant to be exclusive.
What does this decision mean for those appealing NWRB decisions?	This decision means that appeals from NWRB decisions must now be directed to the Court of Appeals, ensuring uniformity in the review process.
What is certiorari jurisdiction?	Certiorari jurisdiction is the power of a higher court to review the decisions or actions of a lower court or tribunal to determine if it acted without jurisdiction or with grave abuse of discretion.
Why is this decision important?	This decision is important because it clarifies the proper venue for appeals from the NWRB, ensuring consistency and predictability in the legal process.

In conclusion, the Supreme Court’s decision in National Water Resources Board v. A. L. Ang Network, Inc. definitively establishes the Court of Appeals as the proper venue for both certiorari and appellate jurisdiction over adjudications of the NWRB. This ruling streamlines the review process and provides clear guidance for parties seeking to appeal NWRB decisions, promoting efficiency and consistency in the administration of water rights disputes.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: National Water Resources Board v. A. L. Ang Network, Inc., G.R. No. 186450, April 08, 2010