Paat vs.

Court of Appeals

Facts: A truck owned by private respondent de Guzman, while en route from Cagayan to Bulacan,
was seized in Nueva Vizcaya by DENR officials for transporting forest products without the required
documents.

Petitioner Layugan, acting as Community Environment and Natural Resources Officer (CENRO) in
Aritao, issued an order of confiscation, giving the owner fifteen (15) days to explain why the truck
should not be forfeited. Howver, respondent failed to submit the required explanation.

DENR sustained Layugan’s action and ordered the forfeiture of the truck. A letter of reconsideration
was filed by the private respondents, which was subsequently denied.

Following the denial of their reconsideration, private respondents submitted a statement indicating
that if their motion was denied, such letter should be treated as an appeal to the Secretary of DENR.

While the appeal was pending before the Secretary, private respondents filed a replevin suit in RTC,
seeking the return of the truck.

The trial court issued a writ ordering the return of the truck, despite a motion to dismiss by
petitioners on the ground that administrative remedies were yet to be exhausted.

Petitioners moved to dismiss the replevin suit, arguing that court intervention was premature due to
the pending administrative forfeiture proceedings.

Issue: Whether the action in RTC may proceed while an administrative forfeiture proceeding is still
pending

Ruling: No. The principle of exhaustion of administrative remedies requires that all available
administrative processes be utilized before seeking judicial intervention. In this case, the private
respondents acknowledged the existence of an administrative forum and sought to appeal to the
Secretary of the DENR, which indicates that they must exhaust these remedies before resorting to
court action. Therefore, the replevin suit should be dismissed for lack of cause of action due to the
failure to exhaust administrative remedies.
Board of Medical Education vs. Alfonso

Facts: The case involves the Philippine Muslim-Christian College of Medicine Foundation, Inc. (the
College) and Lourdes R. Quisumbing, the Secretary of the Department of Education, Culture and
Sports (DECS). The College was founded to train doctors and improve healthcare for Muslim citizens.
However, by 1985, several evaluations by DECS and the Board of Medical Education showed that the
College did not meet the minimum standards for medical schools in the Philippines.

After a series of inspections revealed serious problems with the College's curriculum, faculty
qualifications, and facilities, the Board of Medical Education recommended closing the College.
Despite attempts by the College to dispute these findings, including a request for a re-evaluation,
follow-up inspections confirmed the need for closure. Secretary Quisumbing notified the College of
the decision to close it at the end of the 1988-1989 school year, stating that the decision was final
and could not be appealed.

The College appealed the closure to the Office of the President, which supported the Secretary's
decision. The College then filed Civil Case No. 1385 in the Regional Trial Court to stop the closure,
claiming it was illegal, unfair, and discriminatory. The trial court initially granted a preliminary
injunction against the closure, arguing that the inspections were done in an arbitrary way. The
petitioners, including Secretary Quisumbing, requested a writ of certiorari to cancel the trial court's
order.

Issue: Whether the court can review and override the specialized findings of Board of Medical
Education and the DECS regarding compliance with established norms for medical schools?

Ruling: No. Courts lack the authority to substitute their judgment for that of the Secretary of
Education or the Board of Medical Education on such matters. The court's role is limited to
determining whether the Secretary acted within the scope of their powers and did not exercise them
in a whimsical, capricious, or arbitrary manner.
San Miguel Corporation vs. Secretary of Labor

Facts: Gregorio Yanglay, Jr., an employee of San Miguel Corporation, who was dismissed for allegedly
trafficking in company medicines. Yanglay had worked at the company since 1963 and was earning a
daily wage of fourteen pesos. On April 22, 1972, he was apprehended outside the company premises
carrying drugs worth P267, which he claimed to have bought from coworkers.

Yanglay admitted to possessing the drugs but argued that he believed he was allowed to buy them,
similar to how some workers sold rice rations. He was dismissed on July 19, 1972, after a series of
investigations. The union contended that there was no company rule against such trafficking and that
a lesser penalty than dismissal was warranted.

NLRC ruled in favor of Yanglay, ordering his reinstatement with back wages. San Miguel Corporation
contested this decision, claiming it denied them due process and that the NLRC had abused its
discretion. The Supreme Court ultimately ruled that while Yanglay's actions warranted disciplinary
action, dismissal was too severe, and he should be reinstated without back wages, acknowledging
the company's good faith in the initial dismissal.

Issue: Whether the court has the jurisdiction to review the decisions of the NLRC and the Secretary
of Labor

Ruling: Yes, the Supreme Court has the jurisdiction to review the decisions of the NLRC and the
Secretary of Labor. Judicial review is part of the system of checks and balances that allows courts to
scrutinize the acts of administrative agencies on questions of law and jurisdiction, even if no right of
review is explicitly provided by statute. This ensures that administrative agencies operate within their
jurisdiction and protects the substantial rights of affected parties.
Lovina vs. Moreno

Facts: Primitivo Lovina and Nelly Montilla owned a fishpond in Macabebe, Pampanga. A dispute
arose when local residents petitioned the Secretary of Public Works, alleging that their constructions
obstructed the navigable Sapang Bulati river. After an investigation, the Secretary deemed the
constructions a public nuisance and ordered their removal.

In response, Lovina and Montilla sought a permanent injunction from the Court of First Instance in
Manila to prevent the Secretary from enforcing his order. The trial court granted the injunction,
prompting an appeal from the Secretary and investigator Benjamin Yonson, who argued that the
court erred in several respects.

The Lovinas contended that Republic Act No. 2056 was unconstitutional for granting the Secretary
excessive authority. However, the court determined that the Act merely allowed the Secretary to
remove unauthorized constructions on public navigable streams. Although the trial court concluded
that the Sapang Bulati was not navigable, this lacked evidentiary support. The Supreme Court
stressed that the Secretary's factual findings should be respected unless proven otherwise, and
noted that the lack of an express right to appeal did not preclude judicial review.

Issue: Whether the court must respect the factual findings made by the Secretary of Public Works

Ruling: Yes. Secretary found that the constructions obstructed the navigable river Sapang Bulati,
which was deemed a public nuisance. The trial court's ruling against the Secretary's order was based
on its own findings, which were not supported by substantial evidence, leading to the conclusion
that the Secretary's findings should prevail in the absence of illegality, error of law, fraud, or
imposition.
Province of Aklan vs. Jody King Construction and Development Corp.

Facts: The case involves a contract for the Caticlan Jetty Port. Disputes arose over unpaid amounts,
tax refunds, price escalations, and interest payments, prompting the respondent to sue the
petitioner in the RTC.

RTC ruled in favor of Jody King Construction, ordering Aklan to pay. The petitioner’s motion for
reconsideration was denied due to late filing. Following this, a writ of execution was issued, but the
banks refused payment, citing legal provisions about government liabilities.

The petitioner then filed a petition for certiorari in the CA to challenge the writ and the RTC's ruling,
which was dismissed for lack of grave abuse of discretion. A subsequent petition regarding the denial
of its notice of appeal was also dismissed. The petitioner claimed the RTC lacked jurisdiction and that
the Commission on Audit had primary jurisdiction over money claims against government agencies.

Issue: Whether money claims against government agencies should first be adjudicated by the COA
before being approached in the judicial courts

Ruling: Yes. SC ruled that the COA has primary jurisdiction over money claims against government
agencies. This means that such claims must first be brought before the COA for resolution before any
judicial proceedings can occur. The court emphasized that RTC should have referred the matter to the
COA, and any judgment rendered by the RTC without this referral is void. Therefore, money claims
against government agencies should indeed be adjudicated by the COA prior to being addressed in
the judicial courts.
Republic vs. Gallo

Facts: Michelle Soriano Gallo filed a petition for correction of entries in her Certificate of Live Birth,
seeking to change her name from "Michael" to "Michelle" and her sex from "Male" to "Female." She
also requested the inclusion of her middle name "Soriano," her mother's middle name "Angangan,"
her father's middle name "Balingao," and her parents' marriage date of May 23, 1981. Gallo
supported her petition with various documents, including her diploma and medical certifications.

RTC found her petition sufficient and scheduled a hearing, publishing a Notice for three consecutive
weeks. During the trial, Gallo presented evidence, including testimonies and documents, to support
her claims. The RTC granted her petition on December 7, 2010, stating that the corrections were
harmless and necessary.

The Office of the Solicitor General appealed the decision, arguing that the corrections should fall
under Rule 103 (change of name) rather than Rule 108 (correction of clerical errors). The Court of
Appeals affirmed the RTC's decision, classifying the corrections as clerical errors.

Issue: Whether Gallo failed to exhaust administrative remedies and observe the doctrine of primary
jurisdiction.

Ruling: No. Court ruled that the Republic of the Philippines, through the Office of the Solicitor
General, waived its right to invoke these doctrines by not raising them in a timely manner before the
Regional Trial Court. The Court emphasized that the issues raised by the Republic were factual in
nature, which are not appropriate for review under Rule 45, focusing instead on legal questions.
Thus, Gallo's petition was deemed valid without the need for prior administrative remedies.
Catipon, Jr. vs. Japson

Facts: Catipon graduated from Baguio Colleges Foundation with a Bachelor's in Commerce but had a
1.5 unit deficiency in Military Science. He participated in graduation ceremonies due to a policy
allowing students with deficiencies up to 12 units to graduate. Employed by the Social Security
System (SSS), he incorrectly believed he could substitute his government service for his academic
deficiency when he applied for the CSPE in 1993.

Jerome Japson filed a complaint against Catipon, claiming he falsely stated he graduated in 1993
instead of 1995, after curing his deficiency. The Civil Service Commission-Cordillera Administrative
Region (CSC-CAR) charged him with Dishonesty and other offenses, finding him guilty of Conduct
Prejudicial to the Best Interest of the Service, while exonerating him of other charges. He received a
six-month suspension and revoked CSPE eligibility.

Catipon appealed to the Court of Appeals (CA), which upheld the CSC-CAR's decision, stating he
should have exhausted administrative remedies first and that negligence in completing the
application constituted conduct prejudicial to the service.

Issue: Whether the CA misapplied the doctrine of exhaustion by dismissing Catipon’s petition on the
basis that he had not exhausted the prescribed administrative channels

Ruling: No. CA correctly held that Catipon should have appealed to the Civil Service Commission
instead of directly filing a petition with the CA. The doctrine requires that all administrative remedies
be exhausted before seeking judicial intervention, which Catipon failed to do. His direct appeal to the
CA was deemed premature, as the CSC is the sole arbiter of civil service disputes and is in the best
position to address such matters. Thus, the CA's dismissal was justified based on this principle.
Corsiga vs. Defensor

Facts: The case involves Eduardo P. Corsiga, who used to be the Deputy Administrator of the National
Irrigation Administration (NIA), and Romeo P. Ortizo, a Senior Engineer B at NIA. The issue started
when Corsiga issued a memo that reassigned Ortizo to a different irrigation system. Ortizo disagreed
and filed a complaint for prohibition and injunction in the RTC.

The trial court denied Corsiga's request to dismiss the case, stating it had the authority to handle the
matter. Corsiga then appealed to the Court of Appeals, which supported the trial court's decision.
The appellate court ruled that Ortizo's reassignment was illegal because it violated his right to job
security. They concluded that Ortizo had a permanent appointment and could not be reassigned
without his consent if it meant a lower rank.

Corsiga argued that the RTC did not have jurisdiction, claiming that only the Civil Service Commission
had authority over personnel actions. He believed that Ortizo should have used administrative
remedies first before going to court. However, the Court of Appeals decided that the reassignment
was clearly illegal and that Ortizo's need for quick action justified his choice to go directly to the
courts.

Issue: Whether Ortizo has a cause of action despite not having exhausted the available
administrative remedies

Ruling: No. The Ortizo failed to exhaust available administrative remedies before seeking judicial
intervention. The court emphasized that as an employee of the National Irrigation Administration
(NIA), Ortizo should have first pursued his complaint with the NIA Administrator and, if necessary,
appealed to the Civil Service Commission. The principle of exhaustion of administrative remedies is
not absolute, but Ortizo's case did not meet the exceptions, as the issues involved required factual
determinations rather than being purely legal. Thus, the court found that his action was premature
and dismissed the case.
Secretary of Agriculture and Natural Resources vs. Judge of Court of First Instance, 97 Phil. 125

Facts: Director of Mines approved a lease application from the Minlawi Mining Association. Louis W.
Hora disagreed with this decision and appealed to the Secretary of Agriculture and Natural
Resources. Secretary rejected Hora's appeal, and he got the decision 3. Hora filed a motion for
reconsideration. The Secretary denied this motion, and Hora received that denial. Hora then filed a
complaint in the Court of First Instance, asking to cancel the Secretary's decision.

The petitioners argued that the Court of First Instance did not have the right to hear the case
because Hora's complaint was filed after the 30-day deadline to appeal set by Republic Act No. 739.
Hora argued that the deadline should start from the denial of his motion for reconsideration, not
from the original decision.

Issue: Whether the Court of First Instance had jurisdiction to hear the civil case brought by Hora,
given that the administrative decision was allegedly appealed beyond the statutory 30-day period.

Ruling: No. court concluded that the appeal period is strictly defined and must be adhered to, as
outlined in Section 4 of Republic Act No. 739. Hora received the Secretary's decision on May 18,
1953, and his complaint was filed on August 27, 1953, which exceeded the allowable period for filing
an appeal. Therefore, the Secretary's decision was deemed final and binding, and the court granted
the petition for certiorari and prohibition, dismissing Hora's complaint.
Collector of Internal Revenue vs. Aznar

Facts: The case began when the Collector of Internal Revenue demanded payment from Matias H.
Aznar for alleged income tax deficiencies for the tax years 1945 to 1951. After a reinvestigation, this
amount was reduced. Aznar contested the collection methods, arguing that the right to collect had
prescribed and that the methods employed would cause him irreparable harm. He filed a petition
with the CTA to restrain the Collector from proceeding with the collection through summary
methods of distraint and levy.

The CTA issued an injunction against the Collector, finding that the collection methods were invalid
due to the expiration of the three-year prescriptive period as provided by Section 51(d) of the
National Internal Revenue Code. The Collector then sought a review of this resolution through a
petition for certiorari, arguing that the injunction was improperly issued without requiring Aznar to
post a bond as mandated by Republic Act No. 1125.

Issue: Whether the Collector of Internal Revenue could enforce the collection of alleged income tax
deficiencies through summary administrative methods (i.e., distraint and levy) after the lapse of the
prescribed three-year period.

Ruling: No. Collector of Internal Revenue could not enforce the collection of alleged income tax
deficiencies through summary administrative methods such as distraint and levy after the lapse of
the prescribed three-year period. Court determined that the collection methods were illegal due to
the expiration of the prescriptive period, as outlined in the National Internal Revenue Code.