Aala vs. Uy Case Digest

CRISANTO M. AALA v. REY T.
UY
GR No. 202781
January 10, 2017
Facts:
On July 12, 2011, the Sangguniang Panlungsod of Tagum City's Committee on Finance
conducted a public hearing for the approval of a proposed ordinance. The proposed
ordinance sought to adopt a new schedule of market values and assessment levels of
real properties in Tagum City. It then passed City Ordinance No. 516, s-2011, entitled
An Ordinance Approving the New Schedule of Market Values, its Classification, and
Assessment Level of Real Properties in the City of Tagum. The ordinance was
approved by Mayor Rey T. Uy (Mayor Uy) on November 11, 2011 and was immediately
forwarded to the Sangguniang Panlalawigan of Davao del Norte for review.
On February 7, 2012, the Sangguniang Panlalawigan of Davao del Norte's Committee

on Ways and Means/Games and Amusement issued a report dated February 1, 2012
declaring City Ordinance No. 516, s-2011 valid. It also directed the respondents to
revise the ordinance based on the recommendations of the Provincial Assessor's Office.
Consequently, petitioners returned it to the respondents for modification. As a result of
the amendments introduced to City Ordinance No. 516, s-2011, on March 19, 2012, the
respondents passed City Ordinance No. 558, s-2012 and was approved by Mayor Uy
on April 10, 2012. It was then transmitted for review to the Sangguniang Panlalawigan
of Davao del Norte. The petitioners received the proposed ordinance on April 12, 2012.
On April 30, 2012, Engineer Crisanto M. Aala (Aala) and Colonel Jorge P. Ferido
(Ferido), both residents of Tagum City, filed before the Sangguniang Panlalawigan of
Davao del Norte an Opposition/Objection to City Ordinance No. 558, s-2012. It was
referred to the Committee on Ways and Means/Games and Amusement. The
Committee conducted a hearing to tackle the matters raised in the Opposition.
In their Opposition/Objection, Aala and Ferido asserted that City Ordinance No. 558, s-
2012 violated Sections 130(a), 198(a) and (b), 199(b), and 201 of the Local
Government Code of 1991. They alleged that Sections III C 1, 2, and 3 as well as
Sections III G 1(b) and 4(g) of the proposed ordinance divided Tagum City into different
zones, classified real properties per zone, and fixed its market values depending on
where they were situated without taking into account the "distinct and fundamental
differences ... and elements of value" of each property.
Aala and Ferido asserted that the proposed ordinance classified and valued those
properties located in a predominantly commercial area as commercial, regardless of the
purpose to which they were devoted. According to them, this was erroneous because
real property should be classified, valued, and assessed not according to its location but
on the basis of actual use. Moreover, they pointed out that the proposed ordinance
imposed exorbitant real estate taxes, which the residents of Tagum City could not afford
to pay.
After the hearing, the Sangguniang Panlalawigan of Davao del Norte's Committee on
Ways and Means/Games and Amusement issued Committee Report No.5 dated May 4,
2012, which returned City Ordinance No. 558, s-2012 to the respondents. The
petitioners also directed the Sangguniang Panlungsod of Tagum City to give attention
and due course to the oppositors' concerns.
On May 22, 2012, the Sangguniang Panlungsod of Tagum City issued Resolution No.
808, s-2012 dated May 14, 2012, requesting the Sangguniang Panlalawigan of Davao
del Norte to reconsider its position on City Ordinance No. 558, s-2012.
The Sangguniang Panlalawigan of Davao del Norte issued Resolution No. 428
declaring as invalid Sections III C 1, 2, and 3, Sections III D (1) and (2), and Sections G
1(b) and 4(g) of City Ordinance No. 558, s-2012.
However, on July 9, 2012, the Sangguniang Panlungsod of Tagum City passed

Resolution No. 874, s-2012 declaring City Ordinance No. 558, s-2012 as valid. It
argued that te Sangguniang Panlalawigan of Davao del Norte failed to take action on
City Ordinance No. 558, s-2012 within 30 days from its receipt on April 12, 2012.
Hence, under Section 56(d) of the Local Government Code of 1991, City Ordinance No.
558, s-2012 enjoys the presumption of validity.
On July 13, 2012, City Ordinance No. 558, s-2012 was published in the July 13-19,
2012 issue of Trends and Time, a newspaper of general circulation in Tagum City.
Alarmed by the impending implementation of City Ordinance No. 558, s-2012,

petitioners filed before this Court an original action for Certiorari, Prohibition, and
Mandamus on August 13, 2012. The Petition included a prayer for the issuance of a
temporary restraining order and a writ of preliminary injunction.
In their Petition, petitioners seek to nullify the ordinance on the ground that respondents
enacted it with grave abuse of discretion. Petitioners invoke this Court's original
jurisdiction under Article VIII, Section 5(1) of the Constitution in view of the need to
immediately resolve the issues they have raised.
Issue:
Whether or not the petitioners comply with the doctrine on hierarchy of courts and
exhaustion of administrative remedy?
Held:
No. The Supreme Court denies the Petition for serious procedural errors. The doctrine
on hierarchy of courts is a practical judicial policy designed to restrain parties from
directly resorting to this Court when relief may be obtained before the lower courts. The
logic behind this policy is grounded on the need to prevent "inordinate demands upon
the Court's time and attention which are better devoted to those matters within its
exclusive jurisdiction," as well as to prevent the congestion of the Court's dockets.
Hence, for this Court to be able to "satisfactorily perform the functions assigned to it by
the fundamental charter," it must remain as a "court of last resort." This can be achieved
by relieving the Court of the "task of dealing with causes in the first instance."
As expressly provided in the Constitution, this Court has original jurisdiction "over
petitions for certiorari, prohibition, mandamus, quo warranto, and habeas
corpus."However, this Court has emphasized that the power to issue writs of certiorari,
prohibition, and mandamus does not exclusively pertain to this Court. Rather, it is
shared with the Court of Appeals and the Regional Trial Courts. Nevertheless, "this
concurrence of jurisdiction" does not give parties unfettered discretion as to the choice
of forum. The doctrine on hierarchy of courts is determinative of the appropriate venue
where petitions for extraordinary writs should be filed. Parties cannot randomly select
the court or forum to which their actions will be directed.
There is another reason why this Court enjoins strict adherence to the doctrine on
hierarchy of courts. The doctrine that requires respect for the hierarchy of courts was
created by this court to ensure that every level of the judiciary performs its designated
roles in an effective and efficient manner."
Consequently, this Court will not entertain direct resort to it when relief can be obtained
in the lower courts. This holds especially true when questions of fact are raised. Unlike
this Court, trial courts and the Court of Appeals are better equipped to resolve questions
of fact. They are in the best position to deal with causes in the first instance.
Given the serious procedural errors committed by petitioners, we find no genuine
reason to dwell on and resolve the other issues presented in this case. The factual
issues raised by petitioners could have been properly addressed by the lower courts
had they adhered to the doctrines of hierarchy of courts and exhaustion of
administrative remedies. These rules were established for a reason. While petitioners'
enthusiasm in their advocacy may be admirable, their overzealousness has further
delayed their cause.
Wherefore, the petition for Certiorari, Prohibition, and Mandamus is DISMISSED.

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CRISANTO M. AALA v. REY T.

On February 7, 2012, the Sangguniang Panlalawigan of Davao del Norte's Committee

However, on July 9, 2012, the Sangguniang Panlungsod of Tagum City passed

Alarmed by the impending implementation of City Ordinance No. 558, s-2012,

Wherefore, the petition for Certiorari, Prohibition, and Mandamus is DISMISSED.

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