Case Digest by: Taala, Deirdre Jo Marie C.

Case Title: Tano vs Socrates, G.R. No. 110249, Aug. 21, 1997

Facts:
On Dec 15, 1992, the Sangguniang Panglungsod ng Puerto Princesa enacted an ordinance banning
the shipment of all live fish and lobster outside Puerto Princesa City from January 1, 1993 to
January 1, 1998. Subsequently the Sangguniang Panlalawigan, Provincial Government of Palawan
enacted a resolution prohibiting the catching, gathering, possessing, buying, selling, and shipment
of a several species of live marine coral dwelling aquatic organisms for 5 years, in and coming
from Palawan waters.
Petitioners filed a special civil action for certiorari and prohibition, praying that the court declare
the said ordinances and resolutions as unconstitutional on the ground that the said ordinances
deprived them of the due process of law, their livelihood, and unduly restricted them from the
practice of their trade, in violation of Section 2, Article XII and Sections 2 and 7 of Article XIII of
the 1987 Constitution.

ISSUE:
Are the challenged ordinances unconstitutional?

RULING:
No. The Supreme Court found the petitioners contentions baseless and held that the challenged
ordinances did not suffer from any infirmity, both under the Constitution and applicable laws.
There is absolutely no showing that any of the petitioners qualifies as a subsistence or marginal
fisherman. Besides, Section 2 of Article XII aims primarily not to bestow any right to subsistence
fishermen, but to lay stress on the duty of the State to protect the nation’s marine wealth. The
so-called “preferential right” of subsistence or marginal fishermen to the use of marine resources
is not at all absolute.
In accordance with the Regalian Doctrine, marine resources belong to the state and pursuant to
the first paragraph of Section 2, Article XII of the Constitution, their “exploration, development
and utilization...shall be under the full control and supervision of the State.

In addition, one of the devolved powers of the LCG on devolution is the enforcement of fishery
laws in municipal waters including the conservation of mangroves. This necessarily includes the
enactment of ordinances to effectively carry out such fishery laws within the municipal waters. In
light of the principles of decentralization and devolution enshrined in the LGC and the powers
granted therein to LGUs which unquestionably involve the exercise of police power, the validity
of the questioned ordinances cannot be doubted.
Case Digest by: Taala, Deirdre Jo Marie C.
Case Title: Ysmael Jr. & Co. v. Dep. Executive Secretary, G.R. 79538

FACTS:
In 1986, at the start of President Corazon Aquino’s administration, petitioner sent letters to the
Office of the President and to the Ministry of Natural Resources (MNR) seeking the reinstatement
of its timber license agreement (TLA No. 87), which was cancelled in August 1983 along with nine
other concessions, during the Marcos administration. It alleged that after the its TLA was
cancelled without being given the opportunity to be heard, its logging area was re-awarded to
other logging concessionaires without a formal award or license, as these entities were controlled
or owned by relatives or cronies of deposed President Marcos.

The Ministry ruled that a timber license was not a contract within the due process clause of the
Constitution, but only a privilege which could be withdrawn whenever public interest or welfare
so demands, and that petitioner was not discriminated against in view of the fact that it was
among ten concessionaires whose licenses were revoked in 1983. It also emphasized the fact that
there was currently a total log ban being imposed on the subject areas.

After the logging ban was lifted, petitioner appealed to the Office of the President, but the petition
was denied on the ground that the appeal was prematurely filed, the matter not having been
terminated in the MNR. Hence, petitioner filed with the Supreme Court a petition for certiorari.

ISSUE:

Whether public respondents acted with grave abuse of discretion amounting to lack or excess of
jurisdiction in refusing to overturn administrative orders issued by their predecessors.

RULING:

The refusal of public respondents to reverse final and executory administrative orders does not
constitute grave abuse of discretion amounting to lack or excess of jurisdiction. It is an established
doctrine in this jurisdiction that the decisions and orders of administrative agencies have, upon
their finality, the force and binding effect of a final judgment within the purview of the doctrine
of res judicata. These decisions and orders are as conclusive upon the rights of the affected
parties as though the same had been rendered by a court of general jurisdiction. The rule of res
judicata thus forbids the reopening of a matter once determined by competent authority acting
within their exclusive jurisdiction

Petitioner did not avail of its remedies under the law for attacking the validity of these
administrative actions until after 1986. By the time petitioner sent its letter to the newly
appointed Minister of the MNR requesting for reconsideration, these were already settled
matters as far as petitioner was concerned.

More importantly, the assailed orders of the MNR disclose public policy consideration, which
effectively forestall judicial interference. Public respondents, upon whose shoulders rests the task
of implementing the policy to develop and conserve the country's natural resources, have
indicated an ongoing department evaluation of all timber license agreements entered into, and
permits or licenses issued, under the previous dispensation. A long line of cases establish the
basic rule that the courts will not interfere in matters which are addressed to the sound discretion
of government agencies entrusted with the regulation of activities coming under their special
technical knowledge and training.

Timber licenses, permits and license agreements are the principal instruments by which the State
regulates the utilization and disposition of forest resources to the end that public welfare is
promoted. And it can hardly be gainsaid that they merely evidence a privilege granted by the State
to qualified entities, and do not vest in the latter a permanent or irrevocable right to the particular
concession area and the forest products therein. They may be validly amended, modified,
replaced or rescinded by the Chief Executive when national interests so require. Thus, they are
not deemed contracts within the purview of the due process of law clause.

The Court expresses its concern regarding alleged irregularities in the issuance of timber license
agreements to a number of logging concessionaires. Should the appropriate case be brought
showing a clear grave abuse of discretion on the part of concerned officials with respect to the
implementation of this public policy, the Court will not hesitate to step in. However, in this case,
the Court finds no basis to issue a writ of certiorari and to grant any of the affirmative reliefs
sought.

Petition is dismissed.
Case Digest by: Taala, Deirdre Jo Marie C.
Case Title: Metro Manila Development Authority v. Concerned Residents of Cavite, G.R. No. 171947

Facts:
Respondents filed a complaint before the RTC against several government agencies, among them
the petitioners, for the cleanup, rehabilitation, and protection of the Manila Bay. The complaint
alleged that the water quality of the Manila Bay had fallen way below the allowable standards set
by law, specifically PD 1152. Respondents, as plaintiffs, prayed that petitioners be ordered to
clean the Manila Bay and submit to the RTC a concerted concrete plan of action for the purpose.

RTC rendered a Decision in favor of respondents, ordering the defendant-government agencies

to clean up and rehabilitate Manila Bay.

Petitioners, before the CA, argued that PD 1152 relates only to the cleaning of specific pollution
incidents and do not cover cleaning in general. Apart from raising concerns about the lack of
funds, petitioners also asserted that the cleaning of the Manila Bay is not a ministerial act, which
can be compelled by mandamus.

The CA denied petitioners’ appeal and affirmed the Decision of the RTC in toto. Hence, this
petition.

Issues:

1. Does PD 1152 include a cleanup in general or is it limited only to the cleanup of specific pollution
incidents?
2. Whether or not petitioners may be compelled by mandamus to clean up and rehabilitate the
Manila Bay?

Ruling:

Issue 1:

PD 1152 does not in any way state that the government agencies concerned ought to confine
themselves to the containment, removal, and cleaning operations when a specific pollution
incident occurs. The underlying duty to upgrade the quality of water is not conditional on the
occurrence of any pollution incident.

Even assuming the absence of a categorical legal provision specifically prodding petitioners to
clean up the bay, they and the men and women representing them cannot escape their obligation
to future generations of Filipinos to keep the waters of the Manila Bay clean and clear as humanly
as possible.

Issue 2:

Yes, petitioners may be compelled.

The MMDA’s duty in the area of solid waste disposal is set forth not only in the Environment Code
(PD 1152) and RA 9003, but in its charter as well. This duty of putting up a proper waste disposal
system cannot be characterised as discretionary, for, as earlier stated, discretion presupposes the
power or right given by law to public functionaries to act officially according to their judgment or
conscience.

A perusal of other petitioners’ respective charters would yield to the conclusion that these
government agencies are enjoined, as a matter of statutory obligation, to perform certain
functions relating directly or indirectly to the cleanup, rehabilitation, protection, and preservation
of the Manila Bay. They are precluded from choosing not to perform these duties.

The petition is DENIED.

Case Digest by: Taala, Deirdre Jo Marie C.
Case Title: Africa v. Caltex, G.R. No. 12986

FACTS:

On March 18, 1948 a fire broke out at the Caltex service station at the corner of Antipolo street
and Rizal Avenue, Manila St. all started while a gasoline was being hosed from a tank truck into
the underground storage, right at the opening of the receiving tank where the nozzle of the hose
was inserted. The fire spread to and burned several neighboring house. The spouse Bernabe and
heirs of Domingo Ong herein petitioner, sued respondents Caltex (phils), Inc. and Mateo Boquiren
on negligence on the part of both of tyhem was attributed as the cause of the fire.

In the police and fire report they started that during the transferring of gasoline to the tank truck
an unknown Filipino Citizen lighted a cigarette and threw the burning match stick near the main
valve of the of the paid underground tank. Due to gasoline fumes, fire suddenly blazed. The
respondents contend that it is not their negligence why the fire broke. But there was no evidence
presented to prove this theory and no other explanation can be had as to the reason for the fire.
Apparently also, Caltex and the branch owner failed to install a concrete firewall to contain fire if
in case one happens.

ISSUE:

Whether or not Caltex and Boquiren are liable to pay for damages.

RULING:

Caltex and Boquiren are liable. Though the one who accuses the other of negligence is the one
with burden to prove, in this case the principle of res ipsa loquitor applies. Res ipsa loquitur (the
transaction speaks for itself) which states: “where the thing which caused injury, without fault of
the injured person, is under the exclusive control of the defendant and the injury is such as in the
ordinary course of things does not occur if he having such control use proper care, if affords
reasonable evidence, in the absence of the explanation, that the injury arose from defendant1s
want of care.” Article 1173 states that, the fault on negligence of the obligation consists in the
omission of that diligence which is required by the nature of the obligation and corresponds with
the circumstances of the persons, of the time and of the place. When negligence shows bad faith,
the provisions of article 1171 and 2201 paragraph 2 shall apply. a fired occurred therein an spread
to and burned the neighboring houses. The person who knew or could have known how the fire
started, were Boquiren, Caltex and their employees, but they gave no explanation thereof
whatsoever. It is fair and reasonable inference that the incident happened because of want of
care.
Case Digest by: Taala, Deirdre Jo Marie C.
Case Title: Mead v. Argel, 115 SCRA 256

FACTS:

Petitioner Donald Mead assailed the legal personality of the Provincial Fiscal to file an information
against him for his alleged violation of RA No. 3931 or An Act Creating a National Water and Air
Pollution Control Commission. Petitioner averred that the National Water and Air Pollution
Control Commission created under the said law has the authority to hear cases involving violations
under the same.

ISSUES:

Whether or not the filing of the information by the provincial fiscal was proper.

RULING:

The filing by the Provincial Fiscal of the case was premature sans the findings of the Commission
on the matter.

Petitioner was being sued for the offense of allegedly causing pollution of a waterway (highway
canal)(Sec 9). The Court held that the exclusive authority to determine whether or not ‘pollution’
did exist is vested in the Commission, who is in better position to determine the same for such
requires specialized knowledge of technical and scientific matters which are not ordinarily within
the competence of Fiscals or of those sitting in a court of justice (Sec 8).

Unless the case involves that of nuisance under the Civil Code or until there is a ruling by the
Commission on the alleged act of pollution, no court action shall be initiated (Sec8).

Without a prior determination or finding by the Commission that the provisions of the subject law
had been violated, the provincial Fiscal lacked the authority to file the case against petitioner
Case Digest by: Taala, Deirdre Jo Marie C.
Case Title: Pollution Adjudication Board v. CA, 195 SCRA 112

Facts:
Respondent, Solar Textile Finishing Corporation is involved in bleaching, rinsing and dyeing
textiles with untreated wastewater which were being discharged directly into a canal leading to
the adjacent Tullahan-Tinejeros River. On September 22, 1988, petitioner Pollution Adjudication
Board issued an ex parte Order based on 2 findings made on Solar Textile Finishing Corportion’s
plant, directing Solar immediately to cease and desist from utilizing its wastewater pollution
source installations as they were clearly in violation of Section 8 of Presidential Decree No. 984
(Pollution Control Law) and Section 103 of its Implementing Rules and Regulations and the 1982
Effluent Regulations.

Solar then filed a motion for reconsideration which was granted by the Pollution Adjudication
Board for a temporary operation. However, Solar went to the RTC for certiorari and preliminary
injunction against the Board but the same was dismissed. On appeal, the CA reversed the Order
of dismissal of the trial court and remanded the case for further proceedings.

Petitioner Board claims that under P.D. No. 984, Section 7(a), it has legal authority to issue ex
parte orders to suspend the operations of an establishment when there is prima facie evidence
that such establishment is discharging effluents or wastewater, the pollution level of which
exceeds the maximum permissible standards set by the NPCC (now, the Board). Solar, on the
other hand, contends that under the Board's own rules and regulations, an ex parte order may
issue only if the effluents discharged pose an "immediate threat to life, public health, safety or
welfare, or to animal and plant life" and argued that there were no findings that Solar's
wastewater discharged posed such a threat.

ISSUE:
Whether or not the Pollution Adjudication Board has legal authority to issue the Order and Writ
of Execution against Solar Textile Finishing Corporation. YES.

RULING:
Section 7(a) of P.D. No. 984 authorized petitioner Board to issue ex parte cease and desist orders
under the following circumstances:
(a) Public Hearing. . . . Provided, That whenever the Commission finds prima facie evidence that
the discharged sewage or wastes are of immediate threat to life, public health, safety or welfare,
or to animal or plant life, or exceeds the allowable standards set by the Commission, the
Commissioner may issue an ex-parte order directing the discontinuance of the same or the
temporary suspension or cessation of operation of the establishment or person generating such
sewage or wastes without the necessity of a prior public hearing. The said ex-parte order shall be
immediately executory and shall remain in force until said establishment or person prevents or
abates the said pollution within the allowable standards or modified or nullified by a competent
court.

The Court found that the Order and Writ of Execution issued by petitioner Board were entirely
within its lawful authority Ex parte cease and desist orders are permitted by law and regulations
in situations like in this case. The relevant pollution control statute and implementing regulations
were enacted and promulgated in the exercise of that pervasive, sovereign power to protect the
safety, health, and general welfare and comfort of the public, as well as the protection of plant
and animal life, commonly designated as the police power. It is a constitutional commonplace
that the ordinary requirements of procedural due process yield to the necessities of protecting
vital public interests like those here involved, through the exercise of police power. Hence, the
trial court did not err when it dismissed Solar's petition for certiorari. It follows that the proper
remedy was an appeal from the trial court to the Court of Appeals, as Solar did in fact appeal.

The Court gave due course on the Petition for Review and the Decision of the Court of Appeals
and its Resolution were set aside. The Order of petitioner Board and the Writ of Execution, as well
as the decision of the trial court were reinstated, without prejudice to the right of Solar to contest
the correctness of the basis of the Board's Order and Writ of Execution at a public hearing before
the Board.
Case Digest by: Taala, Deirdre Jo Marie C.
Case Title: Province of Rizal v. Executive Secretary, G.R. No. 129546

FACTS:
The Province of Rizal, the municipality of San Mateo, and various concerned citizens filed a
petition for review on certiorari of the Decision of the Court of Appeals, denying, for lack of cause
of action, the petition for certiorari, prohibition and mandamus with application for a temporary
restraining order/writ of preliminary injunction assailing the legality and constitutionality of
Proclamation No. 635.

Proclamation No. 635 sets aside parts of the Marikina Watershed Reservation for use as a sanitary
landfill and similar waste disposal applications for the solid wastes of Quezon City, Marikina, San
Juan, Mandaluyong, Pateros, Pasig, and Taguig.

Petitioners object to the location of the dumpsites within the watershed because such greatly
affected the ecological balance and environmental factors, including health risks in the
community.

President Joseph E. Estrada issued a Memorandum ordering the closure of the dumpsite on 31
December 2000. Accordingly, on 20 July 1999, the Presidential Committee on Flagship Programs
and Projects and the MMDA entered into a MOA with the Provincial Government of Rizal, the
Municipality of San Mateo, and the City of Antipolo, wherein the latter agreed to further extend
the use of the dumpsite until its permanent closure on 31 December 2000.

On 11 January 2001, President Estrada directed the reopening of the San Mateo dumpsite “in
view of the emergency situation of uncollected garbage in Metro Manila, resulting in a critical and
imminent health and sanitation epidemic.”

The Supreme Court issued a TRO on 24 January 2001 preventing the dumpsites reopening.
Proclamation No. 635 was declared to be illegal. The Supreme Court held that the San Mateo
Landfill to remain permanently closed.

The petition was granted and the Decision of the Court of was REVERSED and SET ASIDE. The
temporary restraining order issued by the Court on 24 January 2001 was also made permanent.

ISSUES:
1. Whether or not Proclamation No. 635 is illegal.
2. Whether or not a MOA would guarantee the permanent closure of the San Mateo Landfill.

RULING:
1. Yes, Proclamation No. 635 was declared illegal. The circumstances under which Proclamation No.
635 was passed also violates Rep. Act No. 7160, or the Local Government Code. Section 16 allows
every local government unit to exercise the powers expressly granted, those necessarily implied
therefrom, as well as powers necessary, appropriate, or incidental for its efficient and effective
governance, and those which are essential to the promotion of the general welfare, which involve,
among other things, promot(ing) health and safety, enhance(ing) the right of the people to a balanced
ecology, and preserv(ing) the comfort and convenience of their inhabitants.
All the municipal mayors of the province of Rizal openly declared their full support for the rally and
notified the MMDA that they would oppose any further attempt to dump garbage in their province.

Under the Local Government Code, therefore, two requisites must be met before a national project
that affects the environmental and ecological balance of local communities can be implemented:
prior consultation with the affected local communities, and prior approval of the project by the
appropriate sanggunian. Absent either of these mandatory requirements, the projects
implementation is illegal.

2. No, the law and the facts indicate that a mere MOA does not guarantee the dumpsites permanent
closure.

Despite the agreement, President Estrada directed the reopening of the San Mateo dumpsite on 11
January 2001. Were it not for the TRO, then President Estradas instructions would have been lawfully
carried out, for as observed in Oposa v. Factoran, the freedom of contract is not absolute.

The SC thus feel there is also the added need to reassure the residents of the Province of Rizal that
this is indeed a final resolution of this controversy, for a brief review of the records of this case
indicates two self-evident facts. First, the San Mateo site has adversely affected its environs,
and second, sources of water should always be protected.
Case Digest by: Taala, Deirdre Jo Marie C.
Case Title: Boracay Foundation v. Province of Aklan, G.R. No. 196870

FACTS:
Claiming that tourist arrivals to Boracay would reach 1 million in the future, respondent Province
of Aklan planned to expand the port facilities at Barangay Caticlan, Municipality of Malay. Thus,
on May 7, 2009, the Sangguniang Panlalawigan of Aklan Province issued a resolution, authorizing
Governor Carlito Marquez to file an application with respondent Philippine Reclamation Authority
(PRA) to reclaim the 2.64 hectares of foreshore area in Caticlan. In the same year, the Province
deliberated on the possible expansion from its original proposed reclamation area of 2.64
hectares to forty (40) hectares in order to maximize the utilization of its resources.

After PRA’s approval, on April 27, 2010, respondent Department of Environment and Natural
Resources-Environmental Management Bureau-Region VI (DENR-EMB RVI) issued to the Province
Environmental Compliance Certificate-R6-1003-096-7100 (the questioned ECC) for Phase 1 of the
Reclamation Project to the extent of 2.64 hectares to be done along the Caticlan side beside the
existing jetty port.

On May 17, 2010, the Province finally entered into a MOA with PRA which stated that the land
use development of the reclamation project shall be for commercial, recreational and institutional
and other applicable uses. It was at this point that the Province deemed it necessary to conduct a
series of public consultation meetings.

On the other hand, the Sangguniang Barangay of Caticlan, the Sangguniang Bayan of the
Municipality of Malay and petitioner Boracay Foundation, Inc. (BFI), an organization composed of
some 160 businessmen and residents in Boracay, expressed their strong opposition to the
reclamation project on environmental, socio-economic and legal grounds.

Despite the opposition, the Province merely noted their objections and issued a notice to the
contractor on December 1, 2010 to commence with the construction of the project. Thus, on June
1, 2011, BFI filed with the Supreme Court the instant Petition for Environmental Protection
Order/Issuance of the Writ of Continuing Mandamus. Thereafter, the Court issued a Temporary
Environmental Protection Order (TEPO) and ordered the respondents to file their respective
comments to the petition.

The Petition was premised on the following grounds, among others:

a) the Province failed to obtain the favorable endorsement of the LGU concerned;
b) the Province failed to conduct the required consultation procedures as required by the Local
Government Code (LGC).

The Province responded by claiming that its compliance with the requirements of DENR-EMB RVI
and PRA that led to the approval of the reclamation project by the said government agencies, as
well as the recent enactments of the Barangay Council of Caticlan and the Sangguniang Bayan of
the Municipality of Malay favorably endorsing the said project, had “categorically addressed all
the issues” raised by the BFI in its Petition. It also considered the Petition to be premature for lack
of cause of action due to the failure of BFI to fully exhaust the available administrative remedies
even before seeking judicial relief.
ISSUES:
WON the petition is premature because petitioner failed to exhaust administrative remedies
before filing this case?
WON there was proper, timely, and sufficient public consultation for the project?

RULING:
On the issue of prematurity due to failure to exhaust administrative remedies
The Court held that the petition is not premature for failing to exhaust administrative remedies
and to observe the hierarchy of courts as claimed by the respondents.

The Court reiterated their ruling in Pagara v. Court of Appeals where they clarified that the rule
regarding exhaustion of administrative remedies is not a hard and fast rule. It is not applicable
where, among others, there are circumstances indicating the urgency of judicial intervention such
as in the instant case. The rule may also be disregarded when it does not provide a plain, speedy
and adequate remedy or where the protestant has no other recourse.

Meanwhile, the new Rules of Procedure for Environmental Cases, A.M. No. 09-6-8-SC, provides a
relief for petitioner under the writ of continuing mandamus, which is a special civil action that
may be availed of “to compel the performance of an act specifically enjoined by law” and which
provides for the issuance of a TEPO “as an auxiliary remedy prior to the issuance of the writ itself.”

The writ of continuing mandamus allows an aggrieved party to file a verified petition in the proper
court when any government agency or instrumentality or officer thereof “unlawfully neglects the
performance of an act which the law specifically enjoins as a duty xxx in connection with the
enforcement or violation of an environmental law rule or regulation or a right therein, xxx and
there is no other plain, speedy and adequate remedy in the ordinary course of law.” Such proper
court may be the Regional Trial Court exercising jurisdiction over the territory where the
actionable neglect or omission occurred, the Court of Appeals, or the Supreme Court.

Here, the Court found that BFI had no other plain, speedy, or adequate remedy in the ordinary
course of law to determine the questions of unique national and local importance raised that
pertain to laws and rules for environmental protection.

Moreover, the writ of continuing mandamus “permits the court to retain jurisdiction after
judgment in order to ensure the successful implementation of the reliefs mandated under the
court’s decision” and, in order to do this, “the court may compel the submission of compliance
reports from the respondent government agencies as well as avail of other means to monitor
compliance with its decision.”

On the issue of whether or not there was proper, timely, and sufficient public consultation for
the project

The Court found that there was no proper, timely, and sufficient public consultation for the
project.

The Local Government Code (LGC) establishes the duties of national government agencies in the
maintenance of ecological balance and requires them to secure prior public consultations and
approval of local government units. In Province of Rizal v. Executive Secretary, the Court
emphasized that, under the Local Government Code, two requisites must be met before a national
project that affects the environmental and ecological balance of local communities can be
implemented: (1) prior consultation with the affected local communities, and (2) prior approval
of the project by the appropriate sanggunian. The absence of either of such mandatory
requirements will render the project’s implementation as illegal.

Here, the Court classified the reclamation project as a national project since it affects the
environmental and ecological balance of local communities. In one ruling, the Court noted that
such national projects mentioned in Section 27 of the LGC include those that may cause pollution
and bring about climate change, among others, such as the reclamation project in this case.

Also, DENR DAO 2003-30 provides that project proponents should “initiate public consultations
early in order to ensure that environmentally relevant concerns of stakeholders are taken into
consideration in the EIA study and the formulation of the management plan”.

Thus, the law requires the Province, being the delegate of the PRA’s power to reclaim land in this
case, to conduct prior consultations and prior approval. However, the information dissemination
conducted months after the ECC had already been issued was insufficient to comply with the
requirements under the LGC.

Furthermore, the lack of prior public consultation and approval is not corrected by the subsequent
endorsement of the reclamation project by the Sangguniang Barangay of Caticlan and the
Sangguniang Bayan in 2012, which were both undoubtedly achieved at the urging and insistence
of the Province.