Universal Robina was fined by the Laguna Lake Development Authority (LLDA) for failing to comply with wastewater standards at its corn oil refinery plant. LLDA ordered Universal Robina to pay over 1.2 million pesos in penalties. Universal Robina appealed to the Court of Appeals, but the court ruled the appeal was improper because Universal Robina did not first exhaust its administrative remedies by appealing LLDA's order to the Department of Environment and Natural Resources Secretary as required. The Supreme Court affirmed this decision, noting the importance of allowing administrative agencies to perform their functions and the opportunity Universal Robina had to provide documents to LLDA to reduce penalties.
Universal Robina was fined by the Laguna Lake Development Authority (LLDA) for failing to comply with wastewater standards at its corn oil refinery plant. LLDA ordered Universal Robina to pay over 1.2 million pesos in penalties. Universal Robina appealed to the Court of Appeals, but the court ruled the appeal was improper because Universal Robina did not first exhaust its administrative remedies by appealing LLDA's order to the Department of Environment and Natural Resources Secretary as required. The Supreme Court affirmed this decision, noting the importance of allowing administrative agencies to perform their functions and the opportunity Universal Robina had to provide documents to LLDA to reduce penalties.
Universal Robina was fined by the Laguna Lake Development Authority (LLDA) for failing to comply with wastewater standards at its corn oil refinery plant. LLDA ordered Universal Robina to pay over 1.2 million pesos in penalties. Universal Robina appealed to the Court of Appeals, but the court ruled the appeal was improper because Universal Robina did not first exhaust its administrative remedies by appealing LLDA's order to the Department of Environment and Natural Resources Secretary as required. The Supreme Court affirmed this decision, noting the importance of allowing administrative agencies to perform their functions and the opportunity Universal Robina had to provide documents to LLDA to reduce penalties.
Universal Robina was fined by the Laguna Lake Development Authority (LLDA) for failing to comply with wastewater standards at its corn oil refinery plant. LLDA ordered Universal Robina to pay over 1.2 million pesos in penalties. Universal Robina appealed to the Court of Appeals, but the court ruled the appeal was improper because Universal Robina did not first exhaust its administrative remedies by appealing LLDA's order to the Department of Environment and Natural Resources Secretary as required. The Supreme Court affirmed this decision, noting the importance of allowing administrative agencies to perform their functions and the opportunity Universal Robina had to provide documents to LLDA to reduce penalties.
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UNIVERSAL ROBINA v LAGUNA LAKE
Antecedent Facts:
Universal Robina is engaged in the manufacture of animal feeds in Bagong
Ilog, Pasig City. LLDA, in its laboratory analysis of UR’s corn oil refinery plants wastewater found that it failed to comply with the government standards under DENR Administrative orders. LLDA, after receiving a phone-complaint conducted another analysis which showed its continued failure to conform to its effluent standards in terms of Total Suspended Solids, Biochemical Oxygen Demand, Color and Oil/Grease. UR notified LLDA of its plan to upgrade the wastewater treatment facility of its corn oil refinery plant in an effort to comply with environmental laws. A resampling was conducted again which showed that the plant finally complied with the standards. Petitioner then requested for the reduction of penalties. After hearing, the LLDA issued its Order to Pay with the amount of 1, 247,000 covering 932 days from initial sampling to re sampling and another 448 days from when the re-sampling was done until April 17, 2007. Petitioner moved to reconsider, praying that it be ordered to pay only 560,000 pesos on grounds that the LLDA erred in first, adopting a straight computation of the periods of violation based on the flawed assumption that petitioner was operating on a daily basis − without excluding, among others, the period during which the LLDA Laboratory underwent rehabilitation work. LLDA denied the petitioners’ move for reconsideration so it appealed to the Court of Appeals. CA confirmed the orders of LLDA. The appellate court held that while petitioner may have offered documentary evidence to support its assertion that the days when it did not operate must be excluded from the computation, the LLDA has the prerogative to disregard the same for being unverified, hence, unreliable. The appellate court went on to chide petitioners petition for certiorari as premature since the law provides for an appeal from decisions 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. Petitioner cites deprivation 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.
ISSUES:
WON the appeal was proper.
RULING:
No, the appeal to the CA is not proper.
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. EO 192, reorganizing the DENR, created the Pollution Adjudication Board which adjudicates pollution cases, including the as arbitrator for determining reparation, or restitution of the damages and losses resulting from pollution. Petitioner had thus available administrative 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 LLDAs findings is at best, speculative and presumptuous. It is noted that during one of the hearings, the LLDA gave petitioner the opportunity to submit within fifteen days.any valid documents to show proof of its non-operating dates that would be necessary for the possible reduction of the accumulated daily penalties, but petitioner failed to comply therewith.