ADMINISTRATIVE LAW

UNIVERSAL ROBINA CORP. (CORN DIVISION), VS. LAGUNA LAKE DEVELOPMENT

AUTHORITY,
[G.R. NO. 191427, MAY 30, 2011]
Doctrines:
The thrust of the doctrine of exhaustion of administrative remedies is that courts must
allow administrative agencies to carry out their functions and discharge their
responsibilities within the specialized areas of their respective competence.
Administrative due process cannot be fully equated with due process in its strict judicial
sense for it is enough that the party is given the chance to be heard before the case
against him is decided.
Facts:
Laguna Lake Development Authority (LLDA), respondent, found that Universal Robina Corp.
failed to comply with government standards provided under Department of Environment and
Natural Resources (DENR) Administrative Orders (DAOs) Nos. 34 and 35, series of 1990. After
conducting hearings, the LLDA resolved that respondent is found to be discharging pollutive
wastewater. Petitioner moved to reconsider however the LLDA denied petitioners motion for
reconsideration and reiterated its order to pay the penalties. Petitioner challenged by certiorari
the orders before the Court of Appeals. The appellate court went on to chide petitioners petition
for certiorari as premature since the law provides for an appeal from decisions or orders of the
LLDA to the DENR Secretary or the Office of the President, a remedy which should have first
been exhausted before invoking judicial intervention.
Issue:
Whether petitioner was deprived of due process and lack of any plain, speedy or adequate
remedy as grounds which exempted it from complying with the rule on exhaustion of
administrative remedies.
Held:
No. The doctrine of exhaustion of administrative remedies is a cornerstone of our judicial
system. The thrust of the rule is that courts must allow administrative agencies to carry out their
functions and discharge their responsibilities within the specialized areas of their respective
competence. The rationale for this doctrine is obvious. It entails lesser expenses and provides
for the speedier resolution of controversies. Comity and convenience also impel courts of
justice to shy away from a dispute until the system of administrative redress has been
completed.Petitioner had thus available administrative remedy of appeal to the DENR
Secretary. Its contrary arguments to show that an appeal to the DENR Secretary would be an
exercise in futility as the latter merely adopts the LLDAs findings is at best, speculative and
presumptuous.
The essence of due process is simply to be heard, or as applied to administrative proceedings,
an opportunity to explain ones side, or an opportunity to seek a reconsideration of the action or

ruling complained of. Administrative due process cannot be fully equated with due process in its
strict judicial sense for it is enough that the party is given the chance to be heard before the
case against him is decided.