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GR Nos. 197592 & 202623

2013-11-27

PROVINCE OF AKLAN v. JODY KING CONSTRUCTION

VILLARAMA, JR., J.

The doctrine of primary jurisdiction holds that if a case is such that its determination requires the expertise, specialized training and knowledge of the proper administrative bodies, relief must first be obtained in an administrative proceeding before a remedy is supplied by the courts even if the matter may well be within their proper jurisdiction.[22] It applies where a claim is originally cognizable in the courts, and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, have been placed within the special competence of an administrative agency. In such a case, the court in which the claim is sought to be enforced may suspend the judicial process pending referral of such issues to the administrative body for its view or, if the parties would not be unfairly disadvantaged, dismiss the case without prejudice.[23]

GR No. 166836

2013-09-04

SAN MIGUEL PROPERTIES v. SEC. HERNANDO B. PEREZ

BERSAMIN, J.

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.[32]

GR No. 186487

2011-08-15

ROSITO BAGUNU v. SPS. FRANCISCO AGGABAO AND ROSENDA ACERIT

BRION, J.

The application of the doctrine of primary jurisdiction, however, does not call for the dismissal of the case below. It need only be suspended until after the matters within the competence of [the Lands Management Bureau] are threshed out and determined. Thereby, the principal purpose behind the doctrine of primary jurisdiction is salutarily served.[38] (Emphases added.)

GR No. 187714

2011-03-08

AQUILINO Q. PIMENTEL v. SENATE COMMITTEE OF WHOLE

CARPIO, J.

x x x It may occur that the Court has jurisdiction to take cognizance of a particular case, which means that the matter involved is also judicial in character. However, if the case is such that its determination requires the expertise, specialized skills and knowledge of the proper administrative bodies because technical matters or intricate questions of fact are involved, then relief must first be obtained in an administrative proceeding before a remedy will be supplied by the courts even though the matter is within the proper jurisdiction of the court. x x x[18]

GR No. 169704

2010-11-17

ALBERT TENG v. ALFREDO S. PAHAGAC

BRION, J.

By disallowing reconsideration of the VA's decision, Section 7, Rule XIX of DO 40-03 and Section 7 of the 2005 Procedural Guidelines went directly against the legislative intent behind Article 262-A of the Labor Code. These rules deny the VA the chance to correct himself[40] and compel the courts of justice to prematurely intervene with the action of an administrative agency entrusted with the adjudication of controversies coming under its special knowledge, training and specific field of expertise. In this era of clogged court dockets, the need for specialized administrative agencies with the special knowledge, experience and capability to hear and determine promptly disputes on technical matters or intricate questions of facts, subject to judicial review, is indispensable.[41] In Industrial Enterprises, Inc. v. Court of Appeals,[42] we ruled that relief must first be obtained in an administrative proceeding before a remedy will be supplied by the courts even though the matter is within the proper jurisdiction of a court.[43]

GR NO. 148106

2006-07-17

EURO-MED LABORATORIES v. PROVINCE OF BATANGAS

CORONA, J.

The doctrine of primary jurisdiction holds that if a case is such that its determination requires the expertise, specialized training and knowledge of an administrative body, relief must first be obtained in an administrative proceeding before resort to the courts is had even if the matter may well be within their proper jurisdiction.[10] It applies where a claim is originally cognizable in the courts and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, have been placed within the special competence of an administrative agency. In such a case, the court in which the claim is sought to be enforced may suspend the judicial process pending referral of such issues to the administrative body for its view[11] or, if the parties would not be unfairly disadvantaged, dismiss the case without prejudice.[12]

GR NO. 143154

2006-06-21

ADVANCED FOUNDATION CONSTRUCTION SYSTEMS CORPORATION v. NEW WORLD PROPERTIES

CHICO-NAZARIO, J.

At this point, We find it necessary to reiterate that our jurisprudence is replete with the rule that findings of fact of quasi-judicial bodies which have acquired expertise because their jurisdiction is confined to specific matters, are accorded not only with respect but even finality if they are supported by substantial evidence.[6] This is because there are certain cases which require the expertise, specialized skills, and knowledge of the proper administrative bodies because technical matters or intricate questions of facts are involved.[7]

GR NO. 160703

2005-09-23

GMA NETWORK v. ABS-CBN BROADCASTING CORPORATION

YNARES-SANTIAGO, J.

In Industrial Enterprises, Inc. v. Court of Appeals,[19] the Court held that:... It may occur that the Court has jurisdiction to take cognizance of a particular case, which means that the matter involved is also judicial in character. However, if the case is such that its determination requires the expertise, specialized skills and knowledge of the proper administrative bodies because technical matters or intricate questions of facts are involved, then relief must first be obtained in an administrative proceeding before a remedy will be supplied by the courts even though the matter is within the proper jurisdiction of a court. This is the doctrine of primary jurisdiction. It applies "where a claim is originally cognizable in the courts, and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, have been placed within the special competence of an administrative body; in such case the judicial process is suspended pending referral of such issues to the administrative body for its view[.][20]

GR NO. 132209

2005-04-29

CARLOS C. BUENDIA v. CITY OF ILIGAN

CHICO-NAZARIO, J.

Time and again, this Court has upheld the doctrine of primary jurisdiction in deference to the specialized expertise of administrative agencies to act on certain matters. As held by the Court in the case of Industrial Enterprises, Inc. v. Court of Appeals:[24] . . . [I]f the case is such that its determination requires the expertise, specialized skills and knowledge of the proper administrative bodies because technical matters or intricate questions of facts are involved, then relief must first be obtained in an administrative proceeding before a remedy will be supplied by the courts even though the matter is within the proper jurisdiction of a court. Therefore, the question of as to who between the City of Iligan and Carlos Buendia has the better right to the water source should have been left to the determination of the NWRB via a timely protest filed during the pendency of the water permit applications. However, said issue could not have been adjudicated upon by the NWRB since the application was never properly contested. Hence, in the absence of a timely protest filed before the NWRB, no water rights controversy arose wherein the NWRB can properly discuss the substantial issues raised by respondent.

GR No. 132684

2002-09-11

HERNANI N. FABIA v. CA

BELLOSILLO, J.

question which is within the jurisdiction of the administrative tribunal prior to the resolution of that question by the administrative tribunal, where the question demands the exercise of sound administrative discretion requiring the special knowledge, experience and services of the administrative tribunal to determine technical and intricate matters of fact, and a uniformity of ruling is essential to comply with the premises of the regulatory statute administered.[9] The objective of the doctrine of primary jurisdiction is to guide a court in determining whether it should refrain from exercising its jurisdiction until after an administrative agency has determined some question or some aspect of some question arising in the proceeding before the court.[10] It applies where claim is originally cognizable in the courts and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, has been placed within the special competence of an administrative body; in such case, the judicial process is suspended pending referral of such issues to the administrative body for its view.[11] However, as correctly observed by respondent MTCP, the rationale behind the prior referral of intra-corporate controversies to the SEC before the public prosecutor could act on them for purposes of criminal prosecution loses significance since the newly enacted law recognizes

GR No. 120287

2002-05-28

G & S TRANSPORT CORPORATION v. CA

BELLOSILLO, J.

In recent years, it has been the jurisprudential trend to apply the doctrine of primary jurisdiction in many cases involving matters that demand the special competence of administrative agencies. It may occur that the Court has jurisdiction to take cognizance of a particular case, which means that the matter involved is also judicial in character. However, if the case is such that its determination requires the expertise, specialized skills and knowledge of the proper administrative bodies because technical matters or intricate questions of facts are involved, then relief must first be obtained in an administrative proceeding before a remedy will be supplied by the courts even though the matter is within the proper jurisdiction of a court. This is the doctrine of primary jurisdiction. It applies "where a claim is originally cognizable in the courts, and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, have been placed within the special competence of an administrative body; in such case the judicial process is suspended pending referral of such issues to the administrative body for its view" x x x x "Uniformity and consistency in the regulation of business entrusted to an administrative agency are secured, and the limited function of review by the judiciary are more rationally exercised, by preliminary resort, for ascertaining and interpreting the circumstances underlying legal issues, to agencies that are better equipped than courts by specialization, by insight gained through experience, and by more flexible procedure" x x x x[39] The propriety of the Order of dismissal of Civil Case No. 95-72586 should render moot and academic the instant petition for review of the Decision of the Court of Appeals in CA-G.R. SP No. 36345, "Two Thousand (2000) Transport Corporation v. Hon. Guillermo L. Loja, Sr., as Judge, RTC of Manila, Branch 26, and G & S Transport Corporation," and in CA-G.R. SP No. 36356, "Nissan Car Lease Philippines, Inc. v. Hon. Guillermo L. Loja, Sr., as Judge, RTC of Manila, Branch 26, and G & S Transport Corporation." It is well settled that the issue of propriety of obtaining a preliminary injunction dies with the main case from which it logically sprang. Such a provisional remedy, like any other interlocutory order, cannot survive the main case of which it is but an incident.[40] Indeed what more could this Court enjoin when the complaint has already been dismissed? To be sure, even a ruling granting the petition at bar would not revive the civil case much less change our ruling in the petition for certiorari under Rule 65.[41] The remedy in question is precisely termed preliminary since it is meant to restrain acts prior to the rendition of a judgment or a final order.[42]

	GR Nos. 197592 & 202623 2013-11-27	PROVINCE OF AKLAN v. JODY KING CONSTRUCTION VILLARAMA, JR., J.
The doctrine of primary jurisdiction holds that if a case is such that its determination requires the expertise, specialized training and knowledge of the proper administrative bodies, relief must first be obtained in an administrative proceeding before a remedy is supplied by the courts even if the matter may well be within their proper jurisdiction.[22] It applies where a claim is originally cognizable in the courts, and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, have been placed within the special competence of an administrative agency. In such a case, the court in which the claim is sought to be enforced may suspend the judicial process pending referral of such issues to the administrative body for its view or, if the parties would not be unfairly disadvantaged, dismiss the case without prejudice.[23]
	GR No. 166836 2013-09-04	SAN MIGUEL PROPERTIES v. SEC. HERNANDO B. PEREZ BERSAMIN, J.
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.[32]
	GR No. 186487 2011-08-15	ROSITO BAGUNU v. SPS. FRANCISCO AGGABAO AND ROSENDA ACERIT BRION, J.
The application of the doctrine of primary jurisdiction, however, does not call for the dismissal of the case below. It need only be suspended until after the matters within the competence of [the Lands Management Bureau] are threshed out and determined. Thereby, the principal purpose behind the doctrine of primary jurisdiction is salutarily served.[38] (Emphases added.)
	GR No. 187714 2011-03-08	AQUILINO Q. PIMENTEL v. SENATE COMMITTEE OF WHOLE CARPIO, J.
x x x It may occur that the Court has jurisdiction to take cognizance of a particular case, which means that the matter involved is also judicial in character. However, if the case is such that its determination requires the expertise, specialized skills and knowledge of the proper administrative bodies because technical matters or intricate questions of fact are involved, then relief must first be obtained in an administrative proceeding before a remedy will be supplied by the courts even though the matter is within the proper jurisdiction of the court. x x x[18]
	GR No. 169704 2010-11-17	ALBERT TENG v. ALFREDO S. PAHAGAC BRION, J.
By disallowing reconsideration of the VA's decision, Section 7, Rule XIX of DO 40-03 and Section 7 of the 2005 Procedural Guidelines went directly against the legislative intent behind Article 262-A of the Labor Code. These rules deny the VA the chance to correct himself[40] and compel the courts of justice to prematurely intervene with the action of an administrative agency entrusted with the adjudication of controversies coming under its special knowledge, training and specific field of expertise. In this era of clogged court dockets, the need for specialized administrative agencies with the special knowledge, experience and capability to hear and determine promptly disputes on technical matters or intricate questions of facts, subject to judicial review, is indispensable.[41] In Industrial Enterprises, Inc. v. Court of Appeals,[42] we ruled that relief must first be obtained in an administrative proceeding before a remedy will be supplied by the courts even though the matter is within the proper jurisdiction of a court.[43]
	GR NO. 148106 2006-07-17	EURO-MED LABORATORIES v. PROVINCE OF BATANGAS CORONA, J.
The doctrine of primary jurisdiction holds that if a case is such that its determination requires the expertise, specialized training and knowledge of an administrative body, relief must first be obtained in an administrative proceeding before resort to the courts is had even if the matter may well be within their proper jurisdiction.[10] It applies where a claim is originally cognizable in the courts and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, have been placed within the special competence of an administrative agency. In such a case, the court in which the claim is sought to be enforced may suspend the judicial process pending referral of such issues to the administrative body for its view[11] or, if the parties would not be unfairly disadvantaged, dismiss the case without prejudice.[12]
	GR NO. 143154 2006-06-21	ADVANCED FOUNDATION CONSTRUCTION SYSTEMS CORPORATION v. NEW WORLD PROPERTIES CHICO-NAZARIO, J.
At this point, We find it necessary to reiterate that our jurisprudence is replete with the rule that findings of fact of quasi-judicial bodies which have acquired expertise because their jurisdiction is confined to specific matters, are accorded not only with respect but even finality if they are supported by substantial evidence.[6] This is because there are certain cases which require the expertise, specialized skills, and knowledge of the proper administrative bodies because technical matters or intricate questions of facts are involved.[7]
	GR NO. 160703 2005-09-23	GMA NETWORK v. ABS-CBN BROADCASTING CORPORATION YNARES-SANTIAGO, J.
In Industrial Enterprises, Inc. v. Court of Appeals,[19] the Court held that:... It may occur that the Court has jurisdiction to take cognizance of a particular case, which means that the matter involved is also judicial in character. However, if the case is such that its determination requires the expertise, specialized skills and knowledge of the proper administrative bodies because technical matters or intricate questions of facts are involved, then relief must first be obtained in an administrative proceeding before a remedy will be supplied by the courts even though the matter is within the proper jurisdiction of a court. This is the doctrine of primary jurisdiction. It applies "where a claim is originally cognizable in the courts, and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, have been placed within the special competence of an administrative body; in such case the judicial process is suspended pending referral of such issues to the administrative body for its view[.][20]
	GR NO. 132209 2005-04-29	CARLOS C. BUENDIA v. CITY OF ILIGAN CHICO-NAZARIO, J.
Time and again, this Court has upheld the doctrine of primary jurisdiction in deference to the specialized expertise of administrative agencies to act on certain matters. As held by the Court in the case of Industrial Enterprises, Inc. v. Court of Appeals:[24] . . . [I]f the case is such that its determination requires the expertise, specialized skills and knowledge of the proper administrative bodies because technical matters or intricate questions of facts are involved, then relief must first be obtained in an administrative proceeding before a remedy will be supplied by the courts even though the matter is within the proper jurisdiction of a court. Therefore, the question of as to who between the City of Iligan and Carlos Buendia has the better right to the water source should have been left to the determination of the NWRB via a timely protest filed during the pendency of the water permit applications. However, said issue could not have been adjudicated upon by the NWRB since the application was never properly contested. Hence, in the absence of a timely protest filed before the NWRB, no water rights controversy arose wherein the NWRB can properly discuss the substantial issues raised by respondent.
	GR No. 132684 2002-09-11	HERNANI N. FABIA v. CA BELLOSILLO, J.
question which is within the jurisdiction of the administrative tribunal prior to the resolution of that question by the administrative tribunal, where the question demands the exercise of sound administrative discretion requiring the special knowledge, experience and services of the administrative tribunal to determine technical and intricate matters of fact, and a uniformity of ruling is essential to comply with the premises of the regulatory statute administered.[9] The objective of the doctrine of primary jurisdiction is to guide a court in determining whether it should refrain from exercising its jurisdiction until after an administrative agency has determined some question or some aspect of some question arising in the proceeding before the court.[10] It applies where claim is originally cognizable in the courts and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, has been placed within the special competence of an administrative body; in such case, the judicial process is suspended pending referral of such issues to the administrative body for its view.[11] However, as correctly observed by respondent MTCP, the rationale behind the prior referral of intra-corporate controversies to the SEC before the public prosecutor could act on them for purposes of criminal prosecution loses significance since the newly enacted law recognizes
	GR No. 120287 2002-05-28	G & S TRANSPORT CORPORATION v. CA BELLOSILLO, J.
In recent years, it has been the jurisprudential trend to apply the doctrine of primary jurisdiction in many cases involving matters that demand the special competence of administrative agencies. It may occur that the Court has jurisdiction to take cognizance of a particular case, which means that the matter involved is also judicial in character. However, if the case is such that its determination requires the expertise, specialized skills and knowledge of the proper administrative bodies because technical matters or intricate questions of facts are involved, then relief must first be obtained in an administrative proceeding before a remedy will be supplied by the courts even though the matter is within the proper jurisdiction of a court. This is the doctrine of primary jurisdiction. It applies "where a claim is originally cognizable in the courts, and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, have been placed within the special competence of an administrative body; in such case the judicial process is suspended pending referral of such issues to the administrative body for its view" x x x x "Uniformity and consistency in the regulation of business entrusted to an administrative agency are secured, and the limited function of review by the judiciary are more rationally exercised, by preliminary resort, for ascertaining and interpreting the circumstances underlying legal issues, to agencies that are better equipped than courts by specialization, by insight gained through experience, and by more flexible procedure" x x x x[39] The propriety of the Order of dismissal of Civil Case No. 95-72586 should render moot and academic the instant petition for review of the Decision of the Court of Appeals in CA-G.R. SP No. 36345, "Two Thousand (2000) Transport Corporation v. Hon. Guillermo L. Loja, Sr., as Judge, RTC of Manila, Branch 26, and G & S Transport Corporation," and in CA-G.R. SP No. 36356, "Nissan Car Lease Philippines, Inc. v. Hon. Guillermo L. Loja, Sr., as Judge, RTC of Manila, Branch 26, and G & S Transport Corporation." It is well settled that the issue of propriety of obtaining a preliminary injunction dies with the main case from which it logically sprang. Such a provisional remedy, like any other interlocutory order, cannot survive the main case of which it is but an incident.[40] Indeed what more could this Court enjoin when the complaint has already been dismissed? To be sure, even a ruling granting the petition at bar would not revive the civil case much less change our ruling in the petition for certiorari under Rule 65.[41] The remedy in question is precisely termed preliminary since it is meant to restrain acts prior to the rendition of a judgment or a final order.[42]

INDUSTRIAL ENTERPRISES v. CA