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Doctrine of Non-Interference
Doctrine of Non-Interference
Having the same power and prerogatives, courts of coequal and coordinate
jurisdiction cannot interfere with each other’s orders and judgments. The
ultimate test to determine the existence of forum shopping is the vexation caused
the courts and the litigants by the repeated invocation of substantially the same
facts, issues and reliefs, thereby unnecessarily clogging court dockets and
creating the possibility of conflicting rulings and decisions.
Thus, we have repeatedly held that a case where an execution order has been
issued is considered as still pending, so that all the proceedings on the
execution are still proceedings in the suit. A court which issued a writ of
execution has the inherent power, for the advancement of justice, to correct
errors of its ministerial officers and to control its own processes. To hold
otherwise would be to divide the jurisdiction of the appropriate forum in the
resolution of incidents arising in execution proceedings-Splitting of jurisdiction is
obnoxious to the orderly administration of justice.
G.R. No. 113357 February 1, 1996
BENJAMIN PAREDES, LUZ BUENSUCESO, AUGUSTO SEVERINO,
RODRIGO TABANERA, STEPHEN SOLIVEN and ROBERTO
SANCHEZ, petitioners,
vs.
COURT OF APPEALS, RIZALINO S. NAVARRO, as Secretary of Trade
and Industry, and IGNACIO S. SAPAL Director of the Bureau of
Patents, Trademarks and Technology Transfer, respondents.
-xxx- that courts should be reluctant to interfere with administrative action prior
to its completion or finality, the reason being that absence of a final order or
decision, the power of the administrative agency concerned has not been fully
exercised and there can be no irreparable harm. The rule of finality of
administrative action for purposes of judicial review also finds substance
in Rochester Telephone Co. vs. U.S. (307 U.S. 125) and Federal Power
Commission vs. Metropolitan Edison Co. (304 U.S. 375). The principle of
exhaustion of administrative remedies which mandates that relief should first be
sought from the highest or most superior administrative agency, the likes of the
Cabinet, may prove that a resort to the courts would be unnecessary (Wee Poco
vs. Posadas, 65 Phil. 648), prevent the courts from being swamped by a resort to
them in the first instance (U.S. vs. Sing Tuck, 194 U.S. 161), strengthened by the
rule on comity and convenience which requires Us to raise our hands until the
administrative process has been finally completed (Matienzo vs. Abellera, supra;
Railroad and Warehouse Commission vs. Duluth, St., R. Co., 273 US 625), and
thus it is after judicial review is no longer premature that the courts may
ascertain, in proper cases, whether the administrative action or findings are not
in violation of law, whether they are free from fraud or imposition and whether
they find substantial support from the evidence
The doctrine of primary jurisdiction has been increasingly called into play on
matters demanding the special competence of administrative agencies even if
such matters are at the same time within the jurisdiction of the courts. A case that
requires for its determination the expertise, specialized skills, and knowledge of
some administrative board or commission because it involves technical matters
or intricate questions of fact, relief must first be obtained in an appropriate
administrative proceeding before a remedy will be supplied by the courts
although the matter comes within the jurisdiction of the courts. The application
of the doctrine does not call for the dismissal of the case in the court
but only for its suspension until after the matters within the
competence of the administrative body are threshed out and
determined.
Under Rule 58, Section 2 of the 1997 Rules of Civil Procedure, the court where
the action is pending may grant the provisional remedy of preliminary injunction.
Generally, trial courts have the ancillary jurisdiction to issue writs of preliminary
injunction in cases falling within its jurisdiction, including civil actions that are
incapable of pecuniary estimation41 and claims for sum of money exceeding
P400,000.00, among others. There are, however, exceptions to this rule -xxx-
-xxx- another exception is that courts could not interfere with the judgments,
orders, or decrees of a court of concurrent or coordinate jurisdiction. This rule of
non-interference applies not only to courts of law having equal rank but also to
quasi-judicial agencies statutorily at par with such courts.