Friday, February 05, 2016

Universal Robina Corporation (Corn Division) vs. Laguna Lake Development Authority (LLDA) GR No. 191427, May 30, 2011

FACTS: Laguna Lake Development Authority (LLDA), respondent, found that Universal Robina Corporation (URC) failed to comply with government standards provided under Department of Environment and Natural Resources (DENR) Administrative Orders (DAOs) Nos. 34 and 35, series of 1990. After conducting hearings, the LLDA resolved that URC is found to be discharging pollutive wastewater. Petitioner moved to reconsider, however, the LLDA denied petitioner's motion for reconsideration and reiterated its order to pay the penalties. Petitioner challenged by certiorari the orders before the Court of Appeals. The appellant court went on to chide petitioner's petition for certiorari as premature since the law provides for an appeal from decision or orders of the LLDA to the DENR Secretary or the Office of the President, a remedy which should have first been exhausted before invoking judicial intervention.

ISSUE: Whether petitioner was deprived of due process and lack of any plain, speedy or adequate remedy as grounds which exempted it from complying with the rule on exhaustion of administrative remedies

RULING: No. The doctrine of exhaustion of administrative remedies is a cornerstone of our judicial system. 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. Petitioner had thus available remedy of appeal to the DENR Secretary. Its contrary arguments to show that an appeal to the DENR Secretary would be an exercise in futility as the latter merely adopts the LLDA's findings is at best, speculative and presumptuous.

The essence of due process is simply to be heard, or as applied to administrative proceedings, an opportunity to explain one's side, or an opportunity to seek a reconsideration of the action or ruling complained of. Administrative due process cannot be fully equated with due process in its strictest judicial sense for it is enough that the party is given the chance to be heard before the case against him is decided.

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