This case has been cited 9 times or more.
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2015-08-24 |
CARPIO, J. |
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| The doctrine of primary administrative jurisdiction precludes trial courts from resolving a controversy involving a question that is within the a exclusive jurisdiction of an administrative tribunal.[107] The doctrine disallows courts "to arrogate unto itself the authority to resolve a controversy the jurisdiction over which is initially lodged with an administrative body of special competence."[108] | |||||
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2015-08-24 |
CARPIO, J. |
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| This court also made a similar ruling in Javier v. Court of Appeals.[118] In Javier, Normito Javier (Normito) was "employed by private respondent Jebsens Maritime, Inc. as a boatswain[.]"[119] Normito, however, died at sea.[120] Upon learning of her husband's death, Lolita Javier (Lolita) went to the office of Jebsens Maritime, Inc. and the latter "promised to give the corresponding death benefits[.]"[121] After Jebsens Maritime, Inc. had failed to pay the promised death benefits, Lolita filed a Complaint before the Regional Trial Court of Makati for a sum of money for herself and on behalf of her six (6) minor children against Jebsens Maritime, Inc. and its shipmaster.[122] | |||||
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2015-08-24 |
CARPIO, J. |
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| This court ruled that under Section 3(d)[123] of Executive Order No. 247 or the Reorganization Act of the Philippine Overseas Employment Administration, it was the Philippine Overseas Employment Administration that had original and exclusive jurisdiction over Lolita's Complaint and that the trial court had no jurisdiction over the subject matter of her Complaint.[124] Hence, under the doctrine of primary administrative jurisdiction, the trial court cannot resolve the controversy.[125] This court ordered the Regional Trial Court to dismiss the case for lack of jurisdiction.[126] | |||||
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2015-08-24 |
CARPIO, J. |
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| Under the doctrine of primary administrative jurisdiction, when an administrative agency is granted primary jurisdiction over the subject matter, the courts "cannot or will not determine a controversy involving a question which is within the jurisdiction of an administrative tribunal prior to the decision of that question by the administrative tribunal[.]"[143] The doctrine of primary administrative jurisdiction presupposes that the administrative agency has jurisdiction over the subject matter while the court does not. The Complaint or Petition, therefore, cannot be filed before the court. As the issue is jurisdictional, there should be no exception to the doctrine of primary administrative jurisdiction. When the complaint or petition is filed before a court with no subject matter jurisdiction, the court has no other option but to dismiss the case.[144] | |||||
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2015-04-24 |
CARPIO, J. |
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| The doctrine of primary administrative jurisdiction precludes trial courts from resolving a controversy involving a question that is within the a exclusive jurisdiction of an administrative tribunal.[107] The doctrine disallows courts "to arrogate unto itself the authority to resolve a controversy the jurisdiction over which is initially lodged with an administrative body of special competence."[108] | |||||
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2015-04-24 |
CARPIO, J. |
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| This court also made a similar ruling in Javier v. Court of Appeals.[118] In Javier, Normito Javier (Normito) was "employed by private respondent Jebsens Maritime, Inc. as a boatswain[.]"[119] Normito, however, died at sea.[120] Upon learning of her husband's death, Lolita Javier (Lolita) went to the office of Jebsens Maritime, Inc. and the latter "promised to give the corresponding death benefits[.]"[121] After Jebsens Maritime, Inc. had failed to pay the promised death benefits, Lolita filed a Complaint before the Regional Trial Court of Makati for a sum of money for herself and on behalf of her six (6) minor children against Jebsens Maritime, Inc. and its shipmaster.[122] | |||||
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2015-04-24 |
CARPIO, J. |
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| This court ruled that under Section 3(d)[123] of Executive Order No. 247 or the Reorganization Act of the Philippine Overseas Employment Administration, it was the Philippine Overseas Employment Administration that had original and exclusive jurisdiction over Lolita's Complaint and that the trial court had no jurisdiction over the subject matter of her Complaint.[124] Hence, under the doctrine of primary administrative jurisdiction, the trial court cannot resolve the controversy.[125] This court ordered the Regional Trial Court to dismiss the case for lack of jurisdiction.[126] | |||||
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2015-04-24 |
CARPIO, J. |
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| Under the doctrine of primary administrative jurisdiction, when an administrative agency is granted primary jurisdiction over the subject matter, the courts "cannot or will not determine a controversy involving a question which is within the jurisdiction of an administrative tribunal prior to the decision of that question by the administrative tribunal[.]"[143] The doctrine of primary administrative jurisdiction presupposes that the administrative agency has jurisdiction over the subject matter while the court does not. The Complaint or Petition, therefore, cannot be filed before the court. As the issue is jurisdictional, there should be no exception to the doctrine of primary administrative jurisdiction. When the complaint or petition is filed before a court with no subject matter jurisdiction, the court has no other option but to dismiss the case.[144] | |||||
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2002-01-04 |
QUISUMBING, J. |
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| x x x The point simply is that when a party commits error in filing his suit or proceeding in a court that lacks jurisdiction to take cognizance of the same, such act may not at once be deemed sufficient basis of estoppel. It could have been the result of an honest mistake, or of divergent interpretations of doubtful legal provisions. If any fault is to be imputed to a party taking such course of action, part of the blame should be placed on the court which shall entertain the suit, thereby lulling the parties into believing that they pursued their remedies in the correct forum. Under the rules, it is the duty of the court to dismiss an action 'whenever it appears that the court has no jurisdiction over the subject matter.' (Sec. 2, Rule 9, Rules of Court) Should the Court render a judgment without jurisdiction, such judgment may be impeached or annulled for lack of jurisdiction (Sec. 30, Rule 132, Ibid), within ten (10) years from the finality of the same. [Emphasis ours.] [24] Indeed, "…the trial court was duty-bound to take judicial notice of the parameters of its jurisdiction and its failure to do so, makes its decision a 'lawless' thing." [25] | |||||