CASE DIGEST
Sugar Regulatory
Administration v. Central Azucarera De Bais, Inc.
G.R. No. 253821, [March 6, 2023]
SECOND, LOPEZ, M.V
Petition for
Certiorari; Pure Questions of Law; Dismissal of improper appeal to the Court of
Appeals.
The following entail pure questions of law—jurisdiction of an administrative agency; whether a litigant is a real party-in-interest; and whether a statute or administrative regulation repealed another.
The Sugar Regulatory Administration
(SRA) issued Sugar Orders that allocated Class "D" world market sugar
to accredited Class "F" ethanol producers. Central Azucarera,
questioning the legality of these orders, filed a Petition for Declaratory
Relief before the Regional Trial Court (RTC). After the parties agreed that
there were no factual issues, Central Azucarera moved for summary judgment. The
RTC ruled in favor of Central Azucarera, declaring the Sugar Orders null and
void, stating that ethanol manufacturers fall under the jurisdiction of the
Department of Energy (DOE), not the SRA. The SRA appealed to the Court of
Appeals (CA), but Central Azucarera argued for dismissal, claiming that the
appeal raised purely legal issues and should have been directly filed with the
Supreme Court. The CA agreed and dismissed the appeal, noting that the
controversy involved purely legal questions and thus should have been addressed
through a petition for review on certiorari before the Supreme Court under Rule
45.
Whether or not the controversy in the
case at bar is purely legal and the SRA should have directly filed an appeal
with the SC.
YES.
The SRA raised pure questions of law in its appeal. Thus, it availed of the
wrong mode of appeal. The Rules of Court outline three modes of appeal from
Regional Trial Court (RTC) decisions: ordinary appeal, petition for review, and
appeal by certiorari. Each mode corresponds to specific circumstances and
allows for different types of questions to be raised. A question of law
pertains to doubts about applicable laws or jurisprudence, without requiring an
assessment of evidence's probative value, while a question of fact involves
disputes over the truth of alleged facts.
In this case, the Sugar Regulatory Administration
(SRA) raised pure questions of law in its appeal regarding the validity and
interpretation of its orders. The issues raised, including the real
party-in-interest status and mootness of the case, are questions of law and do
not necessitate an examination of factual evidence. Therefore, the Court of
Appeals (CA) correctly dismissed the appeal, as the proper mode of review
should have been a petition for review on certiorari to the Supreme Court.
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