Rulings of Cases Ople vs.

Torres (National Computerized System)

An administrative Order must not be contrary to law and shall have the sole purpose of implementing the law. In the case at bar, it is evident that the Order deals with a subject that should be covered by a law and not by mere administrative order because it confers rights and imposes duties.

Lupangco vs. CA
Quasi-judicial adjudication would mean a determination of rights, privileges and duties resulting in a decision or order which applies to a specific situation. This does not cover rules and regulations of general applicability issued by the administrative body to implement its purely administrative policies and functions like Resolution No. 105 which was adopted by the respondent PRC as a measure to preserve the integrity of licensure examinations.

Joson vs. Executive Secretary Torres (jurisdiction of DILG)

Following the provisions of AO 23, the President is the Disciplining Authority while the DILG Secretary or the Special Investigating Committee is the Investigating Authority over actions against elective local officials. Following the alter-ego principle or the qualified political agency, the acts of Secretaries of the departments, in the course of their official duty, are acts of the President unless disapproved by the latter.

Eastern Shipping Lines vs. POEA (valid delegation of legislative power)

The power of subordinate legislation authorizes the POEA to issue rules to be able to carry out the general provisions of the statute. With this power, administrative bodies may implement the broad policies laid down in a statute by filling in the details which the Congress may not have the opportunity or competence to provide.

Fortich vs. Corona (Win-win Resolution)

Administrative Order No. 18 provides that the decisions of the Office of the President shall become final and executory after the lapse of 15 days unless a motion for reconsideration is filed. The Office of the President, by re-opening the case and substantially altering and modifying its decision which had already become final and executory, committed grave abuse of discretion and acted beyond jurisdiction.

Evangelista vs. Jarencio (Subpoena)

EO No. 4 specifically provides that the Presidential Agency on Reforms and Government has power to summon witness, take testimony relevant to the investigation and require production of evidence under subpoena. Administrative agencies have the power to issue subpoena in the course of investigation for the purpose of discovering evidence. The purpose of the subpoena is to discover evidence, not to prove a pending charge.

Kilusang Mayo Uno vs. Garcia Jr (undue delegation of legislative power)

The LTFRB is vested with the power to fix fare rates of public services. But it is not authorized to delegate such power to others such as common carriers, transport operators or other public service. It is contrary to the Latin maxim Potestas delegala non delegari potest. What has been delegated cannot be delegated.

Echegaray vs. Secretary of Justice

What has been delegated cannot be delegated. However, there are certain exceptions. One is delegation of legislative power to administrative bodies. There is no undue delegation of legislative power from Sec of Justice to Director of Bureau of Corrections because the latter is a constituent of the former. The DOJ is tasked to be in charge of the administration of correctional system and has the authority to supervise Director of BOC.

Montes vs. Civil Service Board of Appeals (Exhaustion of Remedies)

The Doctrine of Exhaustion of administrative remedies requires that where an administrative remedy is provided by a statute, relief must be sought by exhausting such remedy first before resorting to the courts so that administrative agencies will have the opportunity to decide the matter itself correctly and prevent unnecessary and premature resort to the courts.

Ledesma vs. CA (SOJs power of supervision and control)

Decisions and resolutions of prosecutors are subject to appeal to the Secretary of Justice who exercises power of direct control and supervision over said prosecutors. He may modify, alter, nullify, or set aside their rulings and substitute it with his own.

US vs. Ang Tang Ho (incomplete law = delegation of legislative power)

A law must be complete in all its terms and provisions and must not be left in the judgment and sole discretion of the delegate of the legislature. The legislature can only enact a law but cannot delegate legislative authority. Act No. 2868 is incomplete and leaves to the Governor General some legislative act.

Taxicab Operators of Manila vs. Board of Transportation

The PD No. 101 grants the Board of Transportation the authority to fix just and reasonable standards, regulations or measures to be imposed and to be followed by the operators of PUV. In the exercise of the powers granted to the Board of Transportation, it shall proceed along the method of legislative inquiry.

SGMC Realty Corp vs. Office of the President (shorter period)

The 30-day period is subject to the qualification that there are no other statutory period of appeal applicable. An administrative rule or regulation, in order to be valid, must no contradict but conform to the provisions of the enabling law. Since there are special laws that mandate a shorter period of 15days, AO No. 18 must give way.

Iglesia ni Cristo vs CA (MTRCBs power to review)

Attack against another religion is a ground for censorship under EO 876 until it was repealed by PD 1986. Its deletion is a decree to disuse it. The ground attack against another religion was merely added by MTRCB in its rules. This rule is void because administrative rules and regulations cannot expand the letter and spirit of the law they seek to enforce.

Romulo vs Home Development Mutual Fund (and/or rule making

power) The HDMF cannot, in the exercise of its rule-making power, issue a regulation not consistent with the law it seeks to apply. Administrative issuances must be within the scope of the statutory authority granted by the legislature to the administrative agency and must not override, supplant or modify the law. Only the Congress can repeal or amend the law.

Republic vs Express Telecom (Exhaustion of Administrative Remedies)

Extelcom violated the rule on exhaustion of administrative remedies when it went directly to the CA on a petition for certiorari and prohibition without first filing a motion for reconsideration with the NTC. A party must exhaust all administrative remedies before resorting to the courts to give the administrative agency a chance to correct itself and to prevent the unnecessary and premature resort to courts. Purely administrative and discretionary powers may not be interfered with by the courts except if the administrative body acted with grave abuse of discretion.

Reformina vs Tomol (authority of the Monetary Board of the Central Bank)

Through Central Bank Circular No. 416, the Monetary Board increased the legal interest rate from 6% to 12% per annum for judgments involving loans or forbearance of money. Any other kind of monetary judgment is not covered by the said law for it is not within the authority granted to the MB. The MB cannot rewrite laws that doesnt fall within its jurisdiction (Art 2209 NCC).

Co vs CA (prospectivity principle)
The prospectivity principle has been made to apply to administrative rulings and circulars. The Circular issued by Minister of Justice that a check issued merely to guarantee the performance of an obligation does not fall within the scope of BP 22, must be prospectively applied to those people who relied on the opinion of the Minister as the proper interpretation of the law, even if such Circular was already repealed.

San Luis vs CA (finality of the decisions of an administrative body)

Since the decisions of both the Civil Service Commissions and the Office of the President had long become final, the same can no longer be reviewed by the courts unless the administrative bodies acted in excess of jurisdiction or with grave abuse of discretion. Final orders and decisions of administrative agencies rendered pursuant to their quasi-judicial authority have the force and binding effect of a final judgment.

Air Manila vs Balatbat (administrative proceedings)

The rule is that administrative proceedings are not exempt from the due process requirements in investigations and trials. The Civil Aeronautics Board did not violate the requisites of administrative due process. The grant of temporary operating permit was issued to prevent stoppage or cessation of services in the affected areas and is a valid exercise of the Boards power.