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SUNVILLE TIMBER PRODUCTS v. ALFONSO G. ABAD AS JUDGE RTC

This case has been cited 5 times or more.

2013-01-14
BERSAMIN, J.
It is axiomatic, to begin with, that a party who seeks the intervention of a court of law upon an administrative concern should first avail himself of all the remedies afforded by administrative processes. The issues that an administrative agency is authorized to decide should not be summarily taken away from it and submitted to a court of law without first giving the agency the opportunity to dispose of the issues upon due deliberation.[16] The court of law must allow the administrative agency to carry out its functions and discharge its responsibilities within the specialized areas of its competence.[17]  This rests on the theory that the administrative authority is in a better position to resolve questions addressed to its particular expertise, and that errors committed by subordinates in their resolution may be rectified by their superiors if given a chance to do so.[18]
2008-09-30
PUNO, C.J.
One of the reasons for the doctrine of exhaustion is the separation of powers, which enjoins upon the Judiciary a becoming policy of non-interference with matters coming primarily (albeit not exclusively) within the competence of the other departments. The theory is that the administrative authorities are in a better position to resolve questions addressed to their particular expertise and that errors committed by subordinates in their resolution may be rectified by their superiors if given a chance to do so... It may be added that strict enforcement of the rule could also relieve the courts of a considerable number of avoidable cases which otherwise would burden their heavily loaded dockets.[22]
2007-07-27
NACHURA, J.
Finally, this Court takes cognizance of petitioners' manifestation that the NPC, as found by the RTC, failed to pay the initial deposit of P32,930.00 as required in PD 42.[33] The RTC had already fixed this amount on the basis of its initial factual findings. The assailed CA Decision adopted the RTC's factual findings. NPC's Comment filed with this Court and even its petition for certiorari before the CA did not address, much less contest, this fact. Because this factual finding was not disputed by the NPC in its pleadings before the CA and before this Court, it is, therefore, deemed admitted.[34] However, inasmuch as petitioners made no mention of this amount in their prayer before this Court, the same shall simply be considered by the RTC and included in the determination of the final just compensation.
2006-08-30
CHICO-NAZARIO, J.
Respondent failed to exhaust administrative remedies when she did not appeal to higher COA authorities the imposition of the P2,000.00 a day penalty. This, notwithstanding, the trial court properly took cognizance of the case and proceeded in hearing the same there being no motion to dismiss filed by petitioner or by defendant Sarmiento on the ground of lack of cause of action. Having failed to invoke this ground at the proper time, that is, in a motion to dismiss, petitioner cannot raise it for the first time on appeal. In Sunville Timber Products, Inc. v. Abad,[15] this Court explained:The doctrine of exhaustion of administrative remedies calls for resort first to the appropriate administrative authorities in the resolution of a controversy falling under their jurisdiction before the same may be elevated to the courts of justice for review. Non-observance of the doctrine results in lack of a cause of action which is one of the grounds allowed in the Rules of Court for the dismissal of the complaint. The deficiency is not jurisdictional. Failure to invoke it operates as a waiver of the objection as a ground for a motion to dismiss and the court may then proceed with the case as if the doctrine had been observed.
2004-12-22
CHICO-NAZARIO, J.
The doctrine of exhaustion of administrative remedies is not absolute, however, there being instances when it may be dispensed with and judicial action may be validly resorted to immediately, among which are: 1) when the question raised is purely legal; 2) when the administrative body is in estoppel; 3) when the act complained of is patently illegal; 4) when there is urgent need for judicial intervention; 5) when the claim involved is small; 6) when irreparable damage will be suffered;[29] 7) when there is no other plain, speedy and adequate remedy; 8) when strong public interest is involved; and 9) in quo warranto proceedings.[30]