Case Digest: Addition Hills v. Megaworld Properties

G.R. No. 175039: April 18, 2012

ADDITION HILLS MANDALUYONG CIVIC & SOCIAL ORGANIZATION, INC.,Petitioner,v. MEGAWORLD PROPERTIES & HOLDINGS, INC., WILFREDO I. IMPERIAL, in his capacity as Director, NCR, and HOUSING AND LAND USE REGULATORY BOARD, DEPARTMENT OF NATURAL RESOURCES,Respondents.

LEONARDO-DE CASTRO, J.:


FACTS:

MEGAWORLD was the registered owner of a parcel of land located along Lee Street, Barangay Addition Hills, Mandaluyong City. It conceptualized the construction of a residential condominium complex on the said parcel of land called the Wack-Wack Heights Condominium consisting of a cluster of six (6) four-storey buildings and one (1) seventeen (17) storey tower. MEGAWORLD thereafter secured the necessary clearances, licenses and permits for the condominium project

Thereafter, construction of the condominium project began, but on June 30, 1995, the plaintiff-appellee AHMCSO filed a complaint before the Regional Trial Court of Pasig City, to annul the Building Permit, CLV, ECC and Development Permit granted to MEGAWORLD; to prohibit the issuance to MEGAWORLD of Certificate of Registration and License to Sell Condominium Units; and to permanently enjoin local and national building officials from issuing licenses and permits to MEGAWORLD.

MEGAWORLD filed a Motion to Dismiss the case for lack of cause of action and that jurisdiction over the case was with the public respondent HLURB and not with the regular courts.

The trial court ruled in favor of petitioner. On appeal, the CA reversed the trial court decision. Hence, the petitioner filed the instant petition.

ISSUE: Whether or not petitioner failed to exhaust all administrative remedies

HELD: Yes. CA Decision Affirmed.

Political Law- doctrine of exhaustion of administrative remedies; doctrine of primary jurisdiction


The thrust of the rule is that courts must allow administrative agencies to carry out their functions and discharge their responsibilities within the specialized areas of their respective competence. The rationale for this doctrine is obvious. It entails lesser expenses and provides for the speedier resolution of controversies. Comity and convenience also impel courts of justice to shy away from a dispute until the system of administrative redress has been completed.

In the case of Republic v. Lacap, the SC held that before a party may seek the intervention of the court, he should first avail of all the means afforded him by administrative processes. The issues which administrative agencies are authorized to decide should not be summarily taken from them and submitted to a court without first giving such administrative agency the opportunity to dispose of the same after due deliberation.

Corollary to the doctrine of exhaustion of administrative remedies is the doctrine of primary jurisdiction; that is, courts cannot or will not determine a controversy involving a question which is within the jurisdiction of the administrative tribunal prior to the resolution of that question by the administrative tribunal, where the question demands the exercise of sound administrative discretion requiring the special knowledge, experience and services of the administrative tribunal to determine technical and intricate matters of fact.

What is apparent, however, is that petitioner unjustifiably failed to exhaust the administrative remedies available with the Housing and Land Use Regulatory Board (HLURB) before seeking recourse with the trial court. Under the rules of the HLURB which were then in effect.

DENIED

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