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Pacific Steam Laundry, Inc. vs. Laguna Lake Development Authority

The document discusses a case where a laundry company was discharging untreated wastewater into a river. The Laguna Lake Development Authority investigated and found violations. The Authority then issued an order to pay a penalty of 172,000 pesos. The issue is whether the Authority's power to impose penalties violates the rule against delegation of legislative powers. The court ruled that the Authority's power to impose fines is not unrestricted, as there are statutory limitations on the Authority's discretion.

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43 views1 page

Pacific Steam Laundry, Inc. vs. Laguna Lake Development Authority

The document discusses a case where a laundry company was discharging untreated wastewater into a river. The Laguna Lake Development Authority investigated and found violations. The Authority then issued an order to pay a penalty of 172,000 pesos. The issue is whether the Authority's power to impose penalties violates the rule against delegation of legislative powers. The court ruled that the Authority's power to impose fines is not unrestricted, as there are statutory limitations on the Authority's discretion.

Uploaded by

John Bas
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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124. Pacific Steam Laundry, Inc. vs.

Laguna Lake Development Authority

Facts:

Petitioner Pacific Steam Laundry, Inc. (petitioner) is a company engaged in the business of laundry
services. On 6 June 2001, the Environmental Management Bureau of the Department of Environment and
Natural Resources (DENR) endorsed to respondent Laguna Lake Development Authority (LLDA) the inspection
report on the complaint of black smoke emission from petitioner’s plant located at 114 Roosevelt Avenue,
Quezon City.3 On 22 June 2001, LLDA conducted an investigation and found that untreated wastewater
generated from petitioner’s laundry washing activities was discharged directly to the San Francisco Del Monte
River. Furthermore, the Investigation Report 4 stated that petitioner’s plant was operating without LLDA
clearance, AC/PO-ESI, and Discharge Permit from LLDA. On 5 September 2001, the Environmental Quality
Management Division of LLDA conducted wastewater sampling of petitioner’s effluent. The result of the
laboratory analysis showed non-compliance with effluent standards

On 16 September 2002, LLDA issued an Order to Pay the accumulated daily penalty amounting to ONE
HUNDRED SEVENTY-TWO THOUSAND (PhP172,000.00) PESOS within fifteen(15) days from receipt hereof as a
condition sine qua non for the dismissal of the above-captioned case. Petitioner asserts that LLDA has no
power to impose fines since such power to impose penal sanctions, which was once lodged with the National
Pollution Control Commission (NPCC), is now assumed by the Pollution Adjudication Board pursuant to
Executive Order No. 192 (EO 192)

Issue: whether or not the grant of implied power to LLDA to impose penalties violate the rule on non-
delegation of legislative powers

Ruling:

No. Delegation of Powers; Laguna Lake Development Authority’s (LLDA’s) power to impose fines is not
unrestricted—there are adequate statutory limitations on LLDA’s power to impose fines which obviates
unbridled discretion in the exercise of such power.—Contrary to petitioner’s contention, LLDA’s power to
impose fines is not unrestricted. In this case, LLDA investigated the pollution complaint against petitioner and
conducted wastewater sampling of petitioner’s effluent. It was only after the investigation result showing
petitioner’s failure to meet the established water and effluent quality standards that LLDA imposed a fine
against petitioner. LLDA then imposed upon petitioner a penalty of P1,000 per day of discharging pollutive
wastewater. The P1,000 penalty per day is in accordance with the amount of penalty prescribed under PD 984:
x x x Clearly, there are adequate statutory limitations on LLDA’s power to impose fines which obviates
unbridled discretion in the exercise of such power.

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