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Tanjay Water District vs. Gabaton

Both petitions were dismissed. In G.R. No. 63742, the trial court’s dismissal of Tanjay Water District’s injunction suit was upheld because the case involved appropriation and utilization of water—a subject matter within the exclusive original jurisdiction of the National Water Resources Council under the Water Code. In G.R. No. 84300, the NLRC’s dismissal of Josefino Datuin’s illegal dismissal complaint was sustained because Section 25 of PD No. 198, which had exempted water district employees from civil service, was repealed by PD No. 1479; thus, water districts are government-owned or controlled corporations with original charters whose personnel fall under civil service law.

Primary Holding

Local water districts formed under PD No. 198, as amended, are government-owned or controlled corporations with original charters; their employees are embraced by the civil service, and the NLRC has no jurisdiction over dismissal disputes involving such employees. Disputes relating to the appropriation, utilization, and control of water must be filed originally with the National Water Resources Council under Articles 88 and 89 of PD No. 1067, the Regional Trial Court exercising only appellate jurisdiction.

Background

Tanjay Water District, a local water district established under PD No. 198, sought to prevent the Municipality of Pamplona and its officials from interfering with its management of the Tanjay Waterworks System. Josefino Datuin, an employee of Tarlac Water District, had been dismissed and obtained a favorable ruling from the Labor Arbiter, only for the NLRC to reverse on the ground that water district employees are covered by the civil service. Both disputes ultimately turned on the same fundamental question: the corporate character of water districts.

History

  1. (G.R. No. 63742) Tanjay Water District filed Civil Case No. 8144 for injunction with preliminary mandatory injunction and damages in the Regional Trial Court of Negros Oriental, 7th Judicial Region, on 3 March 1983.

  2. The RTC directed the parties to submit position papers on jurisdiction. On 25 March 1983, respondent Judge dismissed the complaint for lack of jurisdiction over the subject matter and the parties, holding that jurisdiction lay with the National Water Resources Council and that the dispute should be administratively settled under PD No. 242.

  3. Tanjay Water District elevated the matter to the Supreme Court via a petition for certiorari, alleging grave abuse of discretion.

  4. (G.R. No. 84300) Josefino Datuin filed a complaint for illegal dismissal against Tarlac Water District with the Department of Labor and Employment. The Labor Arbiter ruled in his favor.

  5. On motion for reconsideration treated as an appeal, the NLRC reversed and dismissed the complaint for lack of jurisdiction, holding that Tarlac Water District is a corporation created by a special law and its employees belong to the civil service.

  6. Datuin filed a petition for certiorari with the Supreme Court. The two cases were consolidated by resolution dated 25 July 1988.

Facts

  • G.R. No. 63742 (Tanjay Water District): Tanjay Water District, a local water district created under PD No. 198 and represented by its manager, filed an action for injunction with preliminary mandatory injunction and damages against the Municipality of Pamplona and its officials in the RTC of Negros Oriental. The complaint sought to prevent the municipal respondents from interfering in the management of the Tanjay Waterworks System. Respondents answered and subsequently questioned the court’s jurisdiction, invoking the jurisdiction of the National Water Resources Council under PD No. 1067 (the Water Code) and the administrative settlement mechanism under PD No. 242. The trial court dismissed the complaint, finding that the subject matter—water—fell under Articles 88 and 89 of PD No. 1067 and that the parties, both being government instrumentalities, should settle their dispute administratively pursuant to PD No. 242.

  • G.R. No. 84300 (Datuin): Josefino Datuin was an employee of Tarlac Water District, which was also created under PD No. 198. He filed a complaint for illegal dismissal with the DOLE. The Labor Arbiter decided in his favor. The NLRC, however, reversed, holding that Tarlac Water District is a corporation created by a special law, its officers and employees are part of the civil service, and their separation from office is governed by Civil Service Rules and Regulations.

Arguments of the Petitioners

  • Grave Abuse of Discretion (G.R. No. 63742): Tanjay Water District maintained that respondent Judge acted without or in excess of jurisdiction, or with grave abuse of discretion, in dismissing Civil Case No. 8144.

  • Corporate Character and Labor Jurisdiction (G.R. No. 84300): Datuin argued that Tarlac Water District is a private corporation whose employees are not covered by civil service law, making the NLRC the proper forum for his illegal dismissal complaint. He contended that the issue was identical to that in G.R. No. 63742.

Arguments of the Respondents

  • Lack of Jurisdiction (G.R. No. 63742): The Municipality of Pamplona and its officials argued that the subject matter of the case involved water, thus jurisdiction lay with the National Water Resources Council under Articles 88 and 89 of PD No. 1067. They further asserted that as government instrumentalities, the dispute should be administratively settled under PD No. 242.

  • Civil Service Coverage (G.R. No. 84300): Tarlac Water District contended that it is a government-owned or controlled corporation created by a special law, its employees belong to the civil service, and therefore the NLRC had no jurisdiction over Datuin’s complaint.

Issues

  • Corporate Nature of Water Districts: Whether water districts created under PD No. 198 are government-owned or controlled corporations whose employees fall under the civil service, or private corporations whose employees are subject to the Labor Code.

  • Original Jurisdiction over Water Disputes (G.R. No. 63742): Whether respondent Judge acted without jurisdiction or with grave abuse of discretion in dismissing the injunction suit on the ground that original jurisdiction over water appropriation disputes lies with the National Water Resources Council.

  • Applicability of PD No. 242 (G.R. No. 63742): Whether the dispute between Tanjay Water District and the Municipality of Pamplona should be administratively settled pursuant to PD No. 242.

Ruling

  • Corporate Nature of Water Districts: Local water districts formed under PD No. 198 are quasi-public corporations performing public service—government-owned or controlled corporations with original charters. Section 25 of PD No. 198, which had exempted water district employees from the civil service, was expressly repealed by PD No. 1479. Consequently, the civil service embraces all officers and employees of such water districts. The 1987 Constitution, Article IX-B, Section 2(1), explicitly includes government-owned or controlled corporations with original charters within the civil service. Thus, the NLRC had no jurisdiction over Datuin’s illegal dismissal case.

  • Original Jurisdiction over Water Disputes (G.R. No. 63742): Civil Case No. 8144 involved the appropriation, utilization, and control of water. Under Articles 88 and 89 of PD No. 1067, the National Water Resources Council has exclusive original jurisdiction over all disputes relating to the appropriation, utilization, exploitation, development, control, conservation, and protection of waters. The Regional Trial Court exercises only appellate jurisdiction. The dismissal for lack of jurisdiction was therefore proper.

  • Applicability of PD No. 242 (G.R. No. 63742): PD No. 242 governs disputes solely between or among government instrumentalities arising from the interpretation and application of statutes, contracts, or agreements. The controversy here involved control over water resources, not interpretation of statutes or contracts; thus, PD No. 242 was inapplicable.

Doctrines

  • Repeal of Civil Service Exemption for Water Districts — Section 25 of PD No. 198, which exempted water districts and their employees from civil service, was repealed by Section 3 of PD No. 1479, effective 11 June 1978. The present Section 25 of PD No. 198 (as renumbered by PD No. 1479) deals only with the district’s powers, including eminent domain.

  • Government-Owned or Controlled Corporations with Original Charters — Under Article IX-B, Section 2(1) of the 1987 Constitution, the civil service embraces all branches, subdivisions, instrumentalities, and agencies of the government, including government-owned or controlled corporations with original charters. Water districts created under PD No. 198 possess original charters and thus fall squarely within civil service coverage.

  • Original Jurisdiction of the National Water Resources Council — Articles 88 and 89 of the Water Code (PD No. 1067) vest exclusive original jurisdiction in the National Water Resources Council over all disputes involving appropriation, utilization, exploitation, development, control, conservation, and protection of waters. The Regional Trial Court’s jurisdiction is limited to appellate review of Council decisions.

Key Excerpts

  • “Section 25 of P.D. 198 exempting the employees of water districts from the application of the Civil Service Law was removed from the statute books.” — This crystallizes the effect of PD No. 1479 and is the central factual basis for holding that water district employees are within civil service.

  • “The inclusion of ‘government-owned or controlled corporations’ within the embrace of the civil service shows a deliberate effort of the framers to plug an earlier loophole which allowed government-owned or controlled corporations to avoid the full consequences of the all-encompassing coverage of the civil service system.” — The Court’s explanation, drawn from National Housing Corporation vs. Juco, of the constitutional policy behind civil service coverage.

  • “Inasmuch as PD No. 198, as amended, is the original charter of the petitioner, Tanjay Water District, and respondent Tarlac Water District and all water districts in the country, they come under the coverage of the civil service law, rules and regulations.” — The definitive statement linking local water districts’ original charters to civil service jurisdiction.

Precedents Cited

  • Hagonoy Water District vs. NLRC, G.R. No. 81490, 31 August 1988 — Applied as controlling precedent holding that water districts are quasi-public corporations whose employees belong to the civil service.

  • Baguio Water District vs. Trajano, 127 SCRA 730 (1984) — Applied; the Court relied on this case’s reasoning that PD No. 1479 repealed the civil service exemption of water districts and that they are corporations created under a special law.

  • National Housing Corporation vs. Juco, 134 SCRA 172 (1985) — Quoted with approval on the broad constitutional coverage of the civil service over employees of government-owned or controlled corporations.

Provisions

  • Section 25, Presidential Decree No. 198 (Provincial Water Utilities Act of 1973) — Originally exempted water districts and their employees from civil service. Repealed by PD No. 1479.

  • Sections 3 and 4, Presidential Decree No. 1479 (11 June 1978) — Section 3 repealed Section 25 of PD No. 198; Section 4 renumbered former Section 26 as the new Section 25, thereby erasing the civil service exemption from the statute.

  • Articles 88 and 89, Presidential Decree No. 1067 (Water Code) — Vested original jurisdiction over water disputes in the National Water Resources Council, with appellate review by the Court of First Instance (now Regional Trial Court). Applied to hold that the RTC lacked original jurisdiction over the Tanjay water dispute.

  • Presidential Decree No. 242 (9 July 1973) — Prescribes administrative settlement of disputes between government instrumentalities arising from interpretation of statutes, contracts, or agreements. Held inapplicable to the Tanjay controversy, which concerned water appropriation rather than statutory or contractual interpretation.

  • Section 1, Article XII-B, 1973 Constitution; Section 2(1), Article IX-B, 1987 Constitution — Both provisions mandate that the civil service embraces every government-owned or controlled corporation; the 1987 text explicitly includes those with original charters.

  • Sections 35, Article VIII and 37, Article IX, Presidential Decree No. 807 (Civil Service Decree) — Referenced as the applicable civil service laws and regulations governing water district employees.

Notable Concurring Opinions

Narvasa, Cruz, Gancayco, and Medialdea, JJ., concurred.