Dolot v. Paje

Facts:

On September 15, 2011, petitioner Maricris D. Dolot (Dolot), together with the parish priest of the Holy Infant Jesus Parish and the officers of Alyansa Laban sa Mina sa Matnog (petitioners), filed a petition for continuing mandamus, damages and attorney’s fees with the RTC of Sorsogon. The petition contained the following pertinent allegations: (1) sometime in 2009, they protested the iron ore mining operations being conducted by Antones Enterprises, Global Summit Mines Development Corporation and TR Ore in Barangays Balocawe and Bon-ot Daco, located in the Municipality of Matnog, to no avail; (2) Matnog is located in the southern tip of Luzon and there is a need to protect, preserve and maintain the geological foundation of the municipality; (3) Matnog is susceptible to flooding and landslides, andconfronted with the environmental dangers of flood hazard, liquefaction, ground settlement, ground subsidence and landslide hazard; (4) after investigation, they learned that the mining operators did not have the required permit to operate; (5) Sorsogon Governor Raul Lee and his predecessor Sally Lee issued to the operators a small-scale mining permit, which they did not have authority to issue; (6) the representatives of the Presidential Management Staff and the Department of Environment and Natural Resources (DENR), despite knowledge, did not do anything to protect the interest of the people of Matnog; and (7) the respondents violated Republic Act (R.A.) No. 7076 or the People’s Small-Scale Mining Act of 1991, R.A. No. 7942 or the Philippine Mining Act of 1995, and the Local Government Code.

The RTC dismissed the case for lack of jurisdiction. The petitioners filed an MR but was denied. Dolot went straight to the SC.

Issue:

Whether or not the case was prematurely filed for failure to exhaust administrative remedies.

Held:

None is more well-settled than the rule that jurisdiction, which is the power and authority of the court to hear, try and decide a case, is conferred by law. It may either be over the nature of the action, over the subject matter, over the person of the defendants or over the issues framed in the pleadings. By virtue of Batas Pambansa (B.P.) Blg. 129 or the Judiciary Reorganization Act of 1980, jurisdiction over special civil actions for certiorari, prohibition and mandamus is vested in the RTC. The RTC need not be reminded that venue relates only to the place of trial or the geographical location in which an action or proceeding should be brought and does not equate to the jurisdiction of the court. It is intended to accord convenience to the parties, as it relates to the place of trial, and does not restrict their access to the courts.  At most, the error committed by the petitioners in filing the case with the RTC of Sorsogon was that of improper venue. A.M. No. 09-6-8-SC or the Rules of Procedure for Environmental Cases (Rules) specifically states that a special civil action for continuing mandamus shall be filed with the "[RTC] exercising jurisdiction over the territory where the actionable neglect or omission occurred x x x." In this case, it appears that the alleged actionable neglect or omission occurred in the Municipality of Matnog and as such, the petition should have been filed in the RTC of Irosin.