Remedial Law

REPUBLIC v. TRANSUNION CORPORATION G.R. No. 191590 April 21, 2014 J. Perlas-Bernabe, Judicial Recourse, Exhaustion of Administrative Remedies

FACTS:

Leticia Salamat filed an Application to Purchase Friar Lands with the CENRO of the DENR. Her application was subsequently indorsed to the Land Management Bureau (LMB) for final action. Thereafter, Salamat was informed that subject lot was already covered by a TCT in the name of Transunion. This prompted Salamat to file a Protest against Transunion with the LMB.

Transunion filed with the LMB a motion to dismiss, alleging that Salamat had no legal personality to attack the validity of Transunion’s title, and that it is the RTC which has jurisdiction to try and decide cases involving cancellation of titles. LMB Director Adobo denied the motion to dismiss.

After due proceedings, Atty. Mandar issued an investigation report recommending for the annulment of the subject TCT and the reversion of subject lot to the government. The recommendation was adopted by the Legal Division in its memorandum, which was later approved by the LMB Director.

Neither Salamat nor Transunion were furnished copies of the investigation report or memorandum.

Thereafter, a complaint for cancellation of title and/or reversion  was filed by the Republic against Transunion with the RTC.

Transunion filed a motion to dismiss which was denied by the RTC.

Dissatisfied, Transunion elevated the matter on certiorari.

The CA reversed the RTC’s ruling, observing that no decision was rendered in LMB Case No. 114 and that Transunion was denied the right to be informed of the DENR’s official action as well as the opportunity to contest said action. As such, it pronounced that the filing of the Republic’s reversion complaint was premature and that the latter’s failure to exhaust administrative remedies was fatal to its cause of action.

The Republic filed a motion for reconsideration, which was, however, denied by the CA, hence, this petition.

ISSUE:

Whether or not the CA correctly granted Transunion’s petition for certiorari against the RTC’s order denying the latter’s motion to dismiss.

RULING:

The petition is meritorious.

In the present case, the Court finds that the RTC did not commit any grave abuse of discretion in denying Transunion’s motion to dismiss considering that the latter’s further reconsideration or appeal of the investigation report was not a condition precedent to the filing of the Republic’s reversion complaint. As such, there was no violation of the rule on exhaustion of administrative remedies nor can it be said that the reversion complaint stated no cause of action.

To elaborate, the rule on exhaustion of administrative remedies provides that if a remedy within the administrative machinery can still be resorted to by giving the administrative officer concerned every opportunity to decide on a matter that comes within his jurisdiction, then such remedy should be exhausted first before the court’s judicial power can be sought. The underlying principle of the rule rests on the presumption that the administrative agency, if afforded a complete chance to pass upon the matter will decide the same correctly. It is well-established that the touchstone of due process is the opportunity to be heard.


Leave a Reply

Your email address will not be published.