### Facts:
This case traces back to June 19, 1992, with the enactment of Republic Act No. 7611, the “Strategic Environment Plan (SEP) for Palawan Act,” aiming to protect Palawan’s biodiversity through an Environmentally Critical Areas Network (ECAN). The Palawan Council for Sustainable Development (PCSD) was tasked with enforcing this act, including issuing SEP Clearances for undertakings within the province.
The contention began when the PCSD granted an SEP Clearance to Patricia Louise Mining and Development Corporation (PLMDC) for a small-scale nickel mining project in Barangay Calategas, Narra, Palawan. Local farmers and residents, led by Salvacion Villanueva and others, opposed this, claiming the project was sited in a core zone, contrary to the PCSD’s classification as a controlled use area.
The petitioners initially sought to recall the clearance through a letter to the PCSD, which was denied. Subsequently, on August 7, 2006, they filed a Petition for Certiorari and Mandamus with the Regional Trial Court (RTC) of Palawan and Puerto Princesa City, arguing that the clearance violated provisions of RA 7611 and PCSD resolutions. The RTC initially denied motions to dismiss the case but later dismissed it on jurisdictional grounds, stating that only the Court of Appeals could handle certiorari petitions against quasi-judicial bodies like the PCSD.
The petitioners then escalated the issue to the Supreme Court, contending that the RTC was the appropriate venue due to the localized function of the PCSD and citing the principle of judicial hierarchy.
### Issues:
1. Whether the PCSD exercises quasi-judicial functions in issuing an SEP Clearance.
2. The jurisdictional propriety of filing a Petition for Certiorari against PCSD’s action with the RTC.
3. Whether an ordinary action for nullification is a more appropriate remedy than a Petition for Certiorari for contesting the SEP Clearance’s validity.
### Court’s Decision:
The Supreme Court held that the PCSD did not exercise quasi-judicial functions when issuing an SEP Clearance. It hinged its decision on the fact that RA 7611 does not confer quasi-judicial powers to the PCSD, which primarily oversees the implementation of Palawan’s strategic environmental plan rather than adjudicating disputes. The Court underscored that administrative orders, like PCSD AO 6, cited by the petitioners and the RTC, cannot bestow such powers absent express legislative intent.
As the PCSD does not render decisions affecting the rights of contending parties with finality (a hallmark of quasi-judicial action), its decisions on SEP Clearances cannot be subject to a Petition for Certiorari, which is reserved for acts “without or in excess of jurisdiction, or with grave abuse of discretion.”
Moreover, the Court found the petitioners’ choice of a special civil action (certiorari) improper, considering there was an available and more suitable remedy—an ordinary action for nullification—to address their grievances about the project’s approval, which could fully ventilate factual issues.
### Doctrine:
The Supreme Court underscored that an administrative agency cannot exercise quasi-judicial functions without an explicit grant from the legislature. Furthermore, the choice of remedial action must align with the nature of the agency’s function; certiorari is inappropriate for contesting administrative actions not involving quasi-judicial powers. An ordinary action for nullification serves as the proper recourse when challenging such administrative decisions.
### Class Notes:
– **Quasi-Judicial Functions**: The authority to resolve disputes affecting the rights of parties, akin to a court’s function, granted only by legislation.
– **Certiorari**: A special civil action against a tribunal, board, or officer performing judicial or quasi-judicial acts, viable only under conditions of jurisdictional overreach, grave abuse of discretion, or absence of appeal or adequate remedy.
**Relevant Statutory Provisions**:
– **Republic Act No. 7611 (Strategic Environmental Plan for Palawan Act)**: Does not grant the PCSD quasi-judicial powers. Emphasizes sustainable development and environmental protection in Palawan.
– **Rule 65 of the Rules of Court**: Governs the filing of a Petition for Certiorari.
### Historical Background:
The contention arose in the broader context of balancing environmental protection with development in Palawan, a biodiversity hotspot in the Philippines. The Strategic Environmental Plan for Palawan Act, enacted in 1992, represents a legislative effort to harmonize these interests through a comprehensive framework, marking a significant step in environmental legislation in the Philippines. The dispute in this case underscores ongoing tensions between local development initiatives and the imperative for environmental conservation.
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