Meralco Securities v. Central Board of Assessment Appeals

G.R. No. L-46245 May 31, 1982

Aquino, J.:

Facts: Petitioner questions the decision of the respondent which held that petitioner’s pipeline is subject to realty tax. Pursuant to a concession, petitioner installed a pipeline system from Manila to Batangas. Meanwhile, the provincial assessor of Laguna treated the pipeline as real property. So, petitioner appealed the assessments to the Board of Assessment Appeals of Laguna. The board upheld the assessments and the decision became final and executory after the lapse of fifteen days from the date of receipt of a copy of the decision by the appellant. Meralco Securities contends that the Court of Tax Appeals has no jurisdiction to review the decision of the Central Board of Assessment Appeals and no judicial review of the Board's decision is provided for in the Real Property Tax Code. Hence, the petitioner’s recourse to file a petition for certiorari.

Held: It was held that certiorari was properly availed of in this case. It is a writ issued by a superior court to an inferior court, board or officer exercising judicial or quasi-judicial functions whereby the record of a particular case is ordered to be elevated for review and correction in matters of law.

The rule is that as to administrative agencies exercising quasi-judicial power there is an underlying power in the courts to scrutinize the acts of such agencies on questions of law and jurisdiction even though no right of review is given by the statute. The purpose of judicial review is to keep the administrative agency within its jurisdiction and protect substantial rights of parties affected by its decisions. The review is a part of the system of checks and balances which is a limitation on the separation of powers and which forestalls arbitrary and unjust adjudications. Judicial review of the decision of an official or administrative agency exercising quasi-judicial functions is proper in cases of lack of jurisdiction, error of law, grave abuse of discretion, fraud or collusion or in case the administrative decision is corrupt, arbitrary or capricious.