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CRUSADERS BROADCASTING SYSTEM v. NATIONAL TELECOMMUNICATIONS COMMISSION

This case has been cited 2 times or more.

2001-12-19
QUISUMBING, J.
In Reyes vs. Court of Appeals, G.R. No. 110207, 258 SCRA 651, 658 (1996), we distinguished between the two types of questions: there is a question of law when the doubt or difference arises as to what the law is pertaining to a certain state of facts, and there is a question of fact when the doubt arises as to the truth or falsity of alleged facts. Being a question of fact, it is beyond the office of this court in a petition for review under Rule 45 of the Revised Rules of Court, where only questions of law may be raised.[13] Although there are exceptions,[14] petitioners did not show that this is one of them. Additionally, petitioners, in raising the above issue, is in effect questioning the factual findings of the DARAB, contrary to the doctrine that findings of fact by administrative agencies are generally accorded great respect, if not finality by the courts because of the special knowledge and expertise over matters falling under their jurisdiction.[15] It must be stressed at this point that the DARAB has the jurisdiction on all agrarian disputes involving the implementation of agrarian laws, including PD 27.[16]
2001-11-28
QUISUMBING, J.
As to the second issue, we find applicable the principle of primary jurisdiction, i.e., courts will not interfere in matters which are addressed to the sound discretion of government agencies entrusted with the regulation of activities coming under the special technical knowledge and training of such agencies.[21] Section 3 of PD 957 as amended by Section 8 of Executive Order No. 648 Series of 1981 and further amended by Section 1 (c) of Executive Order No. 90 Series of 1986[22] entrusts to the HLURB the regulation of housing and subdivision developments. Accordingly, the trial court properly relied on the HLURB decision, when said court amended its decision on November 28, 1989. By reason of the special knowledge and expertise of administrative agencies over matters falling under their jurisdiction, they are in a better position to pass judgment thereon. Thus, their findings of fact in that regard are generally accorded great respect, if not finality by the courts.[23]