Facts

Challenge to Regional Trial Court Orders in Camarines Sur

• The Commission on Audit (COA) and several auditors challenged the

Regional Trial Court's (RTC) orders in Camarines Sur.
• The RTC denied the motion to dismiss the auditors against petitions
filed by Luis Raymund Villafuerte, Jr.
• The COA found deficiencies in several disbursements approved by
Villafuerte during his term as Governor of Camarines Sur.
• Villafuerte filed petitions for certiorari and prohibition against
the COA's orders of execution.
• The RTC issued a preliminary injunction enjoining the auditors from
implementing the writ of execution.
• The auditors argued that the RTC had no jurisdiction over the
subject matter and that Villafuerte failed to exhaust administrative
remedies.
• Villafuerte argued that his recourse to the RTC was proper as he
was challenging the ruling of its provincial auditors.
• He claimed that the auditors acted with manifest partiality and
bias.

Issues

Court's Role in RTC's Dismissal of Petitioners' Motion

• Determines if RTC committed grave abuse of discretion.
• Determines propriety of private respondent's recourse to RTC.
• Addresses provincial auditor's NDs.

Rulings:

• The court grants the petition and dismisses petitions filed with
the Regional Trial Court.
• The Notices of Disallowances issued by the Commission on Audit are
affirmed and declared final and executory.
• The jurisdiction of the court and quasi-judicial bodies is
determined by the Constitution and law.
• The principle of primary jurisdiction states that relief must first
be obtained in an administrative proceeding before seeking
remediation from the courts.
• The Supreme Court has the authority to conduct a limited judicial
review of the Commission on Audit acts, decisions, or resolutions.
• The exceptions to the rule on primary jurisdiction do not apply in
this case.
• The Notices of Disallowances have become final and executory, and
the Regional Trial Court has no authority to modify them.