Merida Waterworks District V.

Bacarro
G.R. No. 165993
30 September 2008

Doctrine of Exhaustion of Administrative Remedies

The doctrine of exhaustion of administrative remedies says that a person challenging an
agency decision must first pursue the agency's available remedies before seeking judicial
review. It was created by courts in order to promote an efficient justice system and
autonomous administrative state.

Facts:
● On March 7, 2002, the Merida Water District received a letter from the Local Water
Utilities Administration (LWUA) that on March 5, 2002, the LWUA Boardof Trustees,
per Board Resolution No. 63, series of 2002, confirmed Merida WaterDistrict’s
proposed water rates.
● On September 3, 2002: Merida implemented a water rate increase of P90 for the first
ten cubic meters of water consumption.
● February 13, 2003: consumers of Merida Water District, filed a Petition for
Injunction, etc. because the rates are contrary to the rate increase agreed
upon during the public hearing Merida filed amotion to dismiss (then later motion
for reconsideration) with the RTC due to failure to exhaust administrative remedies
under Presidential Decree (P.D.) No. 198, theProvincial Water Utilities Act of
1973, as amended by P.D. Nos. 768 and 1479 were denied. The CA also denied said
petition; thus, this petition.

Issue:
Whether or not there is lack of jurisdiction with the RTC since the primary jurisdiction should
belong to the NWRB under P.D. No. 1067. (The NWRB does not exercise exclusive
jurisdiction

Held
● Yes. Petitioners failed to cite any law which impliedly grants the NWRBoriginal and
exclusive jurisdiction to resolve a dispute regarding the increase of water rates. A
grant of exclusive jurisdiction cannot be implied from the language of a statute in the
absence of a clear legislative intent to that effect. An administrative agency with
quasi-judicial power is a tribunal of limited jurisdiction, and its jurisdiction should be
interpreted in strictissimi juris.
● The doctrine of exhaustion does not apply when jurisdiction is exclusive. An
Administrative agency’s exclusive jurisdiction over a certain dispute renders the court
without jurisdiction to adjudicate the same at that stage. The doctrine of exhaustion
applies "where a claim is cognizable in the first instance by an administrative agency
alone; judicial intervention is withheld until the administrative process has
run its course. To cite Abe-Abe v. Manta as the authority to support the allegation
that theNWRB has original and exclusive jurisdiction over a dispute regarding a
water rate increase is a strained construction of this Court’s pronouncements. Thus,
petitioners' contention that the RTC has no jurisdiction because the
NWRB has original and exclusive jurisdiction over a dispute concerning the
increase of water rates is clearly without merit.