AEL CASES

Flores vs People
Administrative cases are independent from criminal actions for the same acts or omissions. An
absolution for a criminal charge is not a bar to an administrative prosecution, or vice versa. Given
the differences in the quantum of evidence required, the procedures actually observed, the
sanctions imposed, as well as the objective of the two proceedings, the findings and conclusions in
one should not necessarily be binding on the other.

Phil. Health Insurance Corp. vs COA

PhilHealth personnel cannot be considered public health workers under RA No. 7305
R.A. 7305, the term “health workers” contemplates that an employee
Must be principally tasked to render health or health-related services, such as in hospitals,
sanitaria, health infirmaries, health centers..
Otherwise stated, an employee performing functions not primarily connected with the
delivery of health services to the public is not a public health worker within the contemplation
of the law.
PhilHealth personnel perform functions which pertain to the effective administration of the National
Health Insurance Program or facilitating the availability of funds of health services to its covered
employees…

Philippine Contractors Accreditation Board v. Manila Water Co., Inc

The clear letter of the law is controlling and cannot be amended by mere administrative rule issued
for its implementation.

Department of Trade and Industry v. Enriquez

Department Secretary has no disciplinary jurisdiction over a presidential appointee. Department
Secretary’s power to investigate does not include the power to impose a penalty. Such power
belongs to the appointing authority (or its alter ego). In the absence of a contrary law, the power
to remove or to discipline is lodged in the same authority in whom the power to appoint is
vested.

Sibayan vs Alda
Technical rules of procedure and evidence are not strictly adhered to in administrative
investigations. In Admin cases, it is enough that the parties are given chance to be heard and the
opportunity to adduce their respective sets of evidence.

Office of the Ombudsman v. Mislang

"In administrative cases involving the concurrent jurisdiction of two or more disciplining
authorities, the body in which the complaint is filed first, and which opts to take cognizance of
the case, acquires jurisdiction to the exclusion of other tribunals exercising concurrent
jurisdiction”.

i.e.
Court-martial proceedings contemplate both the penal and administrative disciplinary nature of
military justice. The Ombudsman and the General Court Martial of the AFP have concurring or
coordinate jurisdiction over administrative disciplinary cases involving erring military personnel,
particularly over violations of the Articles of War that are service-connected.

Metro Rail Transit Development Corp. v. Gammon Philippines, Inc

As a rule, findings of fact of administrative agencies and quasi-judicial bodies, which have
acquired expertise because their jurisdiction is confined to specific matters, are generally accorded
not only respect, but also finality, especially when affirmed by the Court of Appeals.

As exceptions, factual findings of construction arbitrators may be reviewed by this Court when the
petitioner proves affirmatively that:
(1) Grave abuse of discretion resulting in lack or loss of jurisdiction as when a party was
deprived of a fair opportunity to present its position before the Arbitral Tribunal or when an
award is obtained through fraud or the corruption of arbitrators,
(2) when the findings of the Court of Appeals are contrary to those of the CIAC, and
(3) when a party is deprived of administrative due process.

In short: GADLEJ, CA has contrary findings, party deprived of admin due process

Ochoa, Jr. v. Buco

As a general rule, only questions of law may be raised in a petition for review on certiorari because
the Court is not a trier of facts. However when the findings of fact of the OP are different from those
of the CA, this court would take a second look at the factual matters surrounding the present case.

Commissioner of Internal Revenue v. Avon Products Manufacturing, Inc.

Administrative due process is anchored on fairness and equity in procedure. It is satisfied if the
party is properly notified of the charge against it and is given a fair and reasonable opportunity to
explain or defend itself. Moreover, it demands that the party's defenses be considered by the
administrative body in making its conclusions, and that the party be sufficiently informed of the
reasons for its conclusions.

Commissioner of Internal Revenue v. V.Y. Domingo Jewellers, Inc.

Under the doctrine of exhaustion of administrative remedies, before a party is allowed to seek the
intervention of the court, he or she should have availed himself or herself of all the means of
administrative processes afforded him or her.

Republic v. Gallo
Doctrine of exhaustion of administrative remedies: a party must first avail of all administrative
processes available before seeking the courts' intervention. The administrative officer concerned
must be given every opportunity to decide on the matter within his or her jurisdiction. Failing to
exhaust administrative remedies affects the party's cause of action as these remedies refer to
a precedent condition which must be complied with prior to filing a case in court. Failure to observe
the doctrine of exhaustion of administrative remedies does not affect the court's jurisdiction.

Doctrine of primary administrative jurisdiction on the other hand is the competence of a court to
take cognizance of a case at first instance. Unlike the doctrine of exhaustion of administrative
remedies, it cannot be waived.

Provincial Bus Operators Association of the Philippines v. DOLE

In constitutional litigation, the Court presumes that official acts of the other branches of the
government are constitutional. In the absence of any clear showing of a breach of the constitutional
text, the validity of the law or action shall be sustained. Burden of proof lies on the party
questioning its validity.
Quasi-legislative: power of admin bodies to enact rules and regulations that have the force and
effect of the law so long as they are issued within the confines of the granting statute.

Quasi-judicial: the power to hear and determine questions of fact to which the legislative policy is to
apply and to decide in accordance with the standards laid down by the law itself in enforcing and
administering the same law.

Lihaylihay v. Tan
The grant of an informer's reward for the discovery, conviction, and punishment of tax offenses is a
discretionary quasi-judicial matter that cannot be the subject of a writ of mandamus because
writ of mandamus must be ministerial rather than discretionary. It is not a legally mandated
ministerial duty.

Metropolitan Manila Development Authority v. D.M. Consunji, Inc.

Commission on Audit and not the RTC that has primary jurisdiction over specific money claim
against a government agency.

Government Service Insurance System v. Daymiel

1.Jurisdiction over a subject matter is conferred by the Constitution or the law, and rules of
procedure yield to substantive law. Otherwise stated, jurisdiction must exist as a matter of law.
Only a statute can confer jurisdiction on courts and administrative agencies. In the exercise of an
administrative agency's quasi-judicial powers, the doctrine of primary jurisdiction may be invoked.

Jaka Investments Corp. v. Urdaneta Village Association, Inc.

Cases involving intra-association controversies fall under the jurisdiction of the Housing and Land
Use Regulatory Board, the government agency with the technical expertise on the matter.

Kilusang Mayo Uno v. Aquino III

Failure to exhaust administrative remedies affects the ripeness to adjudicate the constitutionality of
a governmental act, which in turn affects the existence of the need for an actual case or
controversy for the courts to exercise their power of judicial review.

A case is ripe for adjudication when the challenged governmental act is a completed action such
that there is a direct, concrete, and adverse effect on the petitioner. It is, thus, required that
something had been performed by the government branch or instrumentality before the
court may step in.

Genuino vs de Lima
Before there can even be a valid administrative issuance, there must first be a showing that the
delegation of the legislative power is itself valid.
(a) is so complete in itself, setting forth therein the policy to be executed, carried out, or
implemented by the delegate; and
(b) fixes a standard, the limits of which are sufficiently determinate and determinable to which
the delegate must conform in the performance of his functions.

DOTR vs Phil. Petroleum Sea Transport Association

It is not the proper vehicle to invoke the judicial review powers to declare a statute unconstitutional.
Thus, petitions for certiorari and prohibition are the proper remedies where an action of the
legislative branch is seriously alleged to have infringed the Constitution.

Police power is the plenary power vested in the legislature to make, ordain, and establish
wholesome and reasonable laws, statutes and ordinances, not repugnant to the Constitution, for
the good and welfare of the people

Council of Teachers vs Secretary of Education

Applying the two tests, the Court held that there is no undue delegation of power. When
appreciated in full, the alleged law is complete in all of its essential terms and conditions and
delineates sufficient parameters on the power delegated.

(1) the completeness test, and

the law must be complete in all of its terms and conditions when it leaves the legislature such that
when it reaches the delegate, the only thing he will do is to enforce it.

(2) the sufficient standard test.

there should be adequate and sufficient guidelines in the law to limit the delegate’s authority and to
prevent usurpation of authority.

Cordillera Global Network vs Paje

Gen Rule: Exhaust Admin Remedies
Exception:
1. where the question in dispute is purely a legal one; or
2. where the controverted act is patently illegal or was performed without jurisdiction or in
excess of jurisdiction; or
where the respondent is a department secretary, whose acts as an alter ego of the President
bear the implied or assumed approval of the latter, unless actually disapproved by him; or
where there are circumstances indicating the urgency of judicial intervention;
Where protestant has no other recourse

Galang vs Wallis
The NCIP shall have jurisdiction over claims and disputes involving rights of ICC/IP ONLY WHEN
they arise between or among parties belonging to the same ICC/IP group.

Pimentel vs Legal Education Board

When the PhilSAT is used to exclude, qualify, and restrict admissions to law schools, as its
present design mandates, the PhilSAT goes beyond mere supervision and regulation, violates
institutional academic freedom, becomes unreasonable and therefore, unconstitutional.

Court's exclusive rule-making power covers the practice of law and not the study of law.

Taisei Shimizu vs COA

COA DOES NOT have exclusive jurisdiction over money claims due from or owing to the government.
We recently held that although the COA exercises broad powers pertaining to audit matters, it is devoid of
authority to determine the validity of contracts, lest it encroaches upon such judicial function. We further
decreed that the COA's jurisdiction is limited to audit matters only.

Tourism Infrastructure and Enterprise Zone Authority v. Global-V Builders Co

An Arbitration clause in a construction contract or a submission to arbitration of a construction dispute shall
be deemed an agreement to submit an existing or future controversy to CIAC jurisdiction, notwithstanding
the reference to a different arbitration institution or arbitral body in such contract or submission

Alyansa para sa Bagong Pilipinas, Inc. v. Energy Regulatory Commission

DOE has the power to issue rules and regulations
while ERC has the responsibility to enforce the implementing rules and regulations of the
EPIRA as formulated and adopted by DOE. Nothing whatsoever grants the ERC rule-making
power to supplant or change policies, rules, regulations, or circulars prescribed by the DOE.

Acosta v. Ochoa
The right to bear arms is a mere statutory privilege and not a constitutional right. This privilege is
regulated by the PNP and has the power to approve and disapprove the application of firearms
licenses, as well as revoke the same without violating the due process clause.

The consent form provided is violative of petitioners’ right to privacy and against
unreasonable searches and seizures. In signing this waiver, the requirement of a search warrant
would not apply under this provision. This is not a valid waiver since it does not mention how
the parameters of the inspection shall be conducted. Therefore, the consent form is
unconstitutional.

National Telecommunications Commission v. Brancomm Cable and Television

Network Co
…

Association of International Shipping Lines, Inc. v. Secretary of Finance

when an administrative rule is merely interpretative in nature, its applicability needs nothing
further than its bare issuance, for it gives no real consequence more than what the law itself has
already prescribed.

Sayre y Malampad v. Xenos

The provision in DOJ Circular No. 27 pertaining to acceptable plea bargain for Section 5 of R.A.
9165 did not violate the rule-making authority of the Court. DOJ Circular No. 27 merely serves as
an internal guideline for prosecutors to observe before they may give their consent to proposed
plea bargains.

Antig vs Antipuesto
RTC as a Special Agrarian Court cover only the following controversies
1. All petitions for the determination of just compensation to landowners, and
2. The prosecution of all criminal offenses under RA No. 6657.
=does not include injunction to prevent ARBs from taking over agra land granted to them.

Estrada vs Sandiganbayan
Anti-Money Laundering Council, in investigating probable money laundering activities, does
not exercise quasi-judicial powers, but merely acts as an investigatory body with the sole
power of investigation similar to the functions of the National Bureau of Investigation (NBI)

CSC vs Moralde
A judgment becomes "final and executory" by operation of law. Finality becomes a fact when the
reglementary period to appeal lapses and no appeal is perfected within such period. As a
consequence, no court can exercise appellate jurisdiction to review a case or modify a decision
that has become final. When a final judgment is executory, it becomes immutable and unalterable.
It may no longer be modified in any respect either by the court which rendered it or even by this
Court. The doctrine is founded on considerations of public policy and sound practice that, at the
risk of occasional errors, judgments must become final at some definite point in time.

The doctrine of immutability and inalterability of a final judgment has a two-fold purpose:
(1) to avoid delay in the administration of justice and thus, procedurally, to make orderly the
discharge of judicial business and
(4) to put an end to judicial controversies, at the risk of occasional errors, which is precisely
why courts exist. Controversies cannot drag on indefinitely. The rights and obligations of every
litigant must not hang in suspense for an indefinite period of time.

Republic vs Sandiganbayan
Since notice of sequestration (the action of taking legal possession of assets until a debt has been
paid or other claims have been met) tends to impede or limit the exercise of proprietary rights by
private citizens, it should be construed strictly against the State, pursuant to the legal maxim that
statutes in derogation of common rights are in general strictly construed and rigidly confined to
cases clearly within their scope and purpose.

National Association vs ERC

The basic postulate of due process ordains that the consumers be notified of any application, and be
apprised of its contents, that would result in compounding their economic burden.
The requirement of publication in applications for rate adjustment is not without reason or purpose. It is
ancillary to the due process requirement of notice and hearing. Its purpose is not merely to inform the
consumers that an application for rate adjustment has been filed by the public utility. It is to adequately
inform them that an application has been made for the adjustment of the rates being implemented by the
public utility in order to afford them the opportunity to be heard and submit their stand as to the propriety and
reasonableness of the of the rates within the period allowed by the Rule. Without the publication of the
application, the consumers are left to second-guess the substance and merits of the application.

Miraflores vs Ombudsman
The rule on non-interference is based on the "respect for the investigatory and prosecutor powers
granted by the Constitution to the Office of the Ombudsman.” The Ombudsman has the executive
function and the sole power to determine whether there is probable cause to warrant the filing of a
criminal case against an accused. The SC defers to the sound judgment of the Ombudsman.

Republic vs Apex Mining

Administrative agencies like the DENR enjoy a strong presumption of regularity in the performance
of official duties; they are vested with quasi-judicial powers in enforcing the laws affecting
their respective fields of activity, the proper regulation of which requires of them such technical
mastery of all relevant conditions obtaining in the nation. Unless rebutted by clear and convincing
evidence to the contrary, the presumption becomes conclusive.

The Courts will not interfere in matters which are addressed to the sound discretion of the
government agency entrusted with the regulation of activities coming under the special and
technical training and knowledge of such agency. In their evaluation and exercise of
adjudicative function, administrative agencies are given wide latitude, which includes the authority
to take judicial notice of the facts within their special competence.