This case has been cited 1 times or more.
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2015-07-01 |
CARPIO, J. |
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| Admittedly, we declared in Republic v. Vega that trial courts may grant applications for registration despite the absence of a certification from the DENR Secretary. It should be emphasized, however, that Republic v. Vega applies on a pro hac vice basis only. After Republic v. Vega, we pointed out in Republic v. San Mateo[27] that:In Vega, the Court was mindful of the fact that the trial court rendered its decision on November 13, 2003. way before the rule on strict compliance was laid down in T.A.N. Properties on June 26, 2008. Thus, the trial court was merely applying the rule prevailing at the time, which was substantial compliance. Thus, even if the case reached the Supreme Court after the promulgation of T.A.N. Properties, the Court allowed the application of substantial compliance, because there was no opportunity for the registrant to comply with the Court's ruling in T.A.N. Properties, the trial court and the CA already having decided the case prior to the promulgation of T.A.N. Properties. | |||||