ADMINISTRATIVE LAW CASES

1.Bacani vs. National Coconut Corp.

A dispute arises over whether the National Coconut Corporation is exempt from paying
stenographers' fees, with the court ruling in favor of the stenographers and clarifying that the
corporation is not considered a government entity for the exemption.
Facts:
Plaintiffs Leopoldo T. Bacani and Mateo A. Matoto are court stenographers assigned in Branch
VI of the Court of First Instance of Manila.
During the pendency of Civil Case No. 2293, the National Coconut Corporation (NCC) paid the
plaintiffs stenographers' fees for transcribing the court proceedings.
The Auditor General disallowed the payment of these fees and sought the recovery of the
amounts paid.
The plaintiffs were required to reimburse the amounts based on a circular of the Department of
Justice expressing the opinion that the NCC is not considered a government entity exempt
from paying stenographers' fees.
Issue:
Is the NCC exempt from paying stenographers' fees?
Ruling:
The court ruled in favor of the stenographers, affirming the decision appealed from.
The NCC is not considered a government entity exempt from paying stenographers' fees.
Ratio:
The court based its decision on the interpretation of the term "Government of the Republic of
the Philippines" used in Section 2 of the Revised Administrative Code.
The court clarified that the term refers to a government entity through which the functions of
government are exercised, including the various arms through which political authority is made
effective in the Philippines.
However, the NCC does not fall under the classification of municipal or public corporation, and
therefore, it does not acquire the status of being part of the Government of the Philippines.
The court emphasized that the NCC performs certain functions of government, but this does
not make it a government entity exempt from paying stenographers' fees.
Additionally, the court noted that the stenographers' fees charged by the plaintiffs were within
the prescribed limits set by the rules.
The court also dismissed the procedural question raised by the appellants, stating that the
case does not fall under the specific rule cited by the appellants.

2. Pascual vs. Provincial Board of Nueva Ecija

A municipal mayor in the Philippines seeks protection from an administrative investigation for
alleged misconduct committed during a previous term, as the Supreme Court rules in favor of
the mayor, stating that each term of office is separate and reelection condones previous
misconduct.
Facts:
Arturo B. Pascual was elected as the mayor of San Jose, Nueva Ecija in November 1951 and
reelected in 1955.
On October 6, 1956, the Acting Provincial Governor of Nueva Ecija filed three administrative
charges against Pascual.
One of the charges was for "Maladministrative, Abuse of Authority, and Usurpation of Judicial
Functions."
The charge alleged that Pascual, while serving as the municipal mayor, assumed and usurped
the judicial powers of the justice of the peace.
Pascual accepted a criminal complaint, conducted a preliminary investigation, and reduced the
bail bond of an accused individual.
Issue:
Can a municipal mayor be subjected to an administrative investigation for misconduct
committed during a prior term of office?
Ruling:
The Supreme Court ruled in favor of Pascual and granted the writ of prohibition he sought.
The court held that offenses committed or acts done during a previous term generally do not
provide cause for removal.
Each term of office is separate from other terms, and the reelection to office operates as a
condonation of the officer's previous misconduct, cutting off the right to remove him for such
misconduct.
Therefore, Pascual could not be disciplined for the alleged misconduct committed during his
previous term.
Ratio:
The court based its decision on the principle that each term of office is separate, and the
reelection of an official condones any previous misconduct.
The penalty for removal from office should not extend beyond removal and disqualification
from holding office for the term for which the officer was elected or appointed.
The rule requiring exhaustion of administrative remedies before seeking judicial relief does not
apply when the question in dispute is purely legal and no administrative remedy is provided or
when there is grave doubt about the availability of the administrative remedy.

3. CALO VS. FUERTES

Francisco C. Calo's special civil action for certiorari and prohibition is dismissed after he
withdraws his appeal to the President of the Philippines, resulting in the finality of the Court of
First Instance's judgment against him in a land dispute case.
Facts:
Francisco C. Calo filed a claim and contest against the homestead application of Delfin C.
Fuertes in Butuan City, Philippines.
The Director of Lands denied and dismissed Calo's claim and ordered him to vacate the
premises within sixty days.
Calo requested reconsideration, but it was denied.
Calo brought the case to the Secretary of Agriculture and Natural Resources, who modified the
opinion and ordered Fuertes to reimburse Calo for the improvements made on the land.
Dissatisfied with this decision, Calo appealed to the President of the Philippines but later
withdrew the appeal.
Calo filed a petition for certiorari and prohibition with the Court of First Instance of Agusan,
seeking to enjoin the enforcement of the opinions of the Director of Lands and the Secretary of
Agriculture and Natural Resources.
Issue:
Does Calo's withdrawal of his appeal to the President of the Philippines affect the availability of
certiorari and prohibition as remedies?
Ruling:
The court dismissed Calo's petition for certiorari and prohibition.
The withdrawal of his appeal to the President of the Philippines is considered as not appealing
at all.
The appeal to the President is the last step in an administrative case, and the withdrawal is
fatal.
Certiorari and prohibition are only available when there is no appeal or any plain, speedy, and
adequate remedy in the ordinary course of law.
In this case, the appeal to the President is the plain, speedy, and adequate remedy available to
Calo.
The appeal was not perfected within the reglementary period due to the late filing of the appeal
bond.
Ratio:
The withdrawal of an appeal to the President of the Philippines is equivalent to not appealing
at all.
The appeal to the President is the final step in an administrative case.
Certiorari and prohibition are only available when there is no other plain, speedy, and adequate
remedy in the ordinary course of law.
In this case, the appeal to the President is the appropriate remedy.
The appeal was not perfected within the reglementary period due to the late filing of the appeal
bond.

4. Central Bank of the Philippines vs. Court of Appeals

A construction company sues the Central Bank of the Philippines for breach of contract after
being advised to stop construction due to government policy, and the court rules in favor of the
company, awarding damages for work done, unrealized profits, and attorney's fees.
Facts:
Dispute between Central Bank of the Philippines (petitioner) and Ablaza Construction &
Finance Corporation (respondent) over a construction contract for a regional office building in
San Fernando, La Union.
Respondent commenced construction work on the project but was later advised by the
petitioner to stop due to the government's policy of economic restraint.
Negotiations for the settlement of the respondent's claims on the contract were unsuccessful.
Respondent sued the petitioner for damages for breach of contract.
Trial court ruled in favor of the respondent and awarded damages.
Petitioner appealed to the Court of Appeals, but the judgment was affirmed.
Supreme Court reviewed the case and upheld the lower court's decision.
Issue:
Whether there was a perfected contract between the petitioner and respondent.
Whether the petitioner committed a breach of contract.
Whether the petitioner gave its approval to the work done by the respondent.
Whether the award of damages is fair and reasonable.
Ruling:
The court ruled in favor of the respondent on all issues.
The court upheld the lower court's decision and awarded damages for actual work done,
unrealized profits, and attorney's fees.
Ratio:
Perfection of Contract:
The court held that there was a perfected contract between the parties.
Acceptance of the respondent's bid and the commencement of construction work constituted
an actionable agreement.
The absence of a formal contract did not invalidate the agreement.
Breach of Contract:
The court found that the petitioner's withdrawal from the contract was not justified by the policy
of economic restraint.
The contract was already perfected before the issuance of the memorandum circular
announcing the policy.
Impairing the obligations of the contract is not constitutionally permissible.
Approval of Work:
The court held that the petitioner's approval of the work done by the respondent was not
necessary.
The petitioner's actuations and attitude prior to a certain date indicated that the execution of
the formal contract was not indispensable.
The petitioner must be considered as having waived the requirement of formal contract
execution.
Award of Damages:
The court upheld the award of damages for actual work done and unrealized profits, as well as
attorney's fees.
Indemnification for damages includes not only the value of the loss suffered but also the profits
which the creditor fails to obtain.
The amount of damages awarded by the lower court was found to be fair and reasonable
based on the evidence presented.
However, the court reduced the award for attorney's fees to ten percent of the total recovery.
Overall Decision:
The court affirmed the decision of the Court of Appeals in favor of respondent Ablaza
Construction and Finance Corporation.
The court modified the attorney's fees award.

5. Zambales Chromite Mining Co. vs. Court of Appeals

A mining dispute between Zambales Chromite Mining Co. and the Secretary of Agriculture and
Natural Resources is brought to the Supreme Court, which rules that it was improper for the
Secretary to review his own decision and orders the case to be remanded for a new review by
an impartial official.
Facts:
The case involves a mining dispute between the petitioners (Zambales Chromite Mining Co.
and others) and the respondents (Secretary of Agriculture and Natural Resources, Director of
Mines, and others).
The case was decided by the Second Division of the Supreme Court of the Philippines on
November 7, 1979.
In Mines Administrative Case No. V-227, Director Gozon dismissed the case filed by the
petitioners, who sought to be declared the rightful and prior locators and possessors of sixty-
nine mining claims in Zambales.
Director Gozon found that the petitioners did not discover any mineral nor staked and located
mining claims in accordance with the law.
He ruled that the mining claims of the Martinez and Pabilo a groups, now the private
respondents, were duly located and registered.
The petitioners appealed to the Secretary of Agriculture and Natural Resources, but Director
Gozon, who had been appointed as Secretary, decided the appeal himself.
He ruled that the petitioners had abandoned the disputed mining claims, while the Martinez
and Pabilo a groups had validly located the claims.
The petitioners then filed a complaint in the Court of First Instance of Zambales, challenging
Secretary Gozon's decision.
The lower court upheld Secretary Gozon's decision, stating that the disqualification of a judge
to review his own decision does not apply to administrative bodies.
The petitioners appealed to the Court of Appeals, which initially reversed the trial court's
judgment and declared the petitioners as the rightful locators and possessors of the mining
claims.
However, in a second decision, the Court of Appeals set aside its first decision and remanded
the case to the Minister of Natural Resources for further review.
Issue:
Whether it was proper for Secretary Gozon to review his own decision as Director of Mines.
Ruling:
The Court of Appeals held that it was improper for Secretary Gozon to review his own decision
as Director of Mines.
The case should be remanded to the Minister of Natural Resources for another review.
The Supreme Court agreed with the Court of Appeals and set aside Secretary Gozon's
decision.
The second decision of the Court of Appeals was affirmed, ordering the case to be returned to
the Minister of Natural Resources for a new review.
The trial court's jurisdiction over the case was terminated.
Ratio:
The Supreme Court ruled that Secretary Gozon's actions were a mockery of administrative
justice and a violation of due process.
It is improper for an administrative official to review his own decision.
The principle of disqualification of a judge to review his own decision should also apply to
administrative bodies.
Secretary Gozon's decision was biased and lacked impartiality.
The case should be remanded to the Minister of Natural Resources for a new review by an
impartial official.
The trial court does not retain jurisdiction over the case once it is remanded to the Minister of
Natural Resources.

6. MALABA VS. RAMENTO

The Supreme Court ruled in favor of student petitioners in the case of Malabanan v. Ramento,
nullifying their suspension for holding an illegal assembly and reducing the penalty to one
week, while emphasizing the importance of protecting students' rights to freedom of speech
and peaceable assembly, but also acknowledging the need for reasonable restrictions to
maintain order in educational institutions.
Facts:
Petitioners are officers of the Supreme Student Council of Gregorio Araneta University
Foundation.
They sought and were granted a permit to hold a meeting on August 27, 1982.
They held a general assembly at the Veterinary Medicine and Animal Science basketball court.
They later marched towards the Life Science Building and continued their rally outside the area
covered by their permit.
The rally resulted in disturbance of classes and stoppage of work by non-academic personnel.
Petitioners were suspended for one academic year for holding an illegal assembly.
Issue:
Whether the suspension of the petitioners violated their constitutional rights to freedom of
speech and peaceable assembly.
Ruling:
The Supreme Court ruled in favor of the petitioners.
The Court nullified the suspension and reduced the penalty to one week.
Ratio:
The rights to peaceable assembly and free speech are guaranteed to students of educational
institutions.
These rights should not be subjected to previous restraint or subsequent punishment unless
there is a clear and present danger to a substantive evil that the state has a right to prevent.
The content of placards displayed or utterances made during assemblies should be accorded
utmost leeway and scope.
However, the peaceable character of an assembly can be lost if there is an advocacy of
disorder under the name of dissent.
In granting permits for assemblies held in school premises, school authorities should exercise
discretion and may impose conditions to avoid disruption of classes or stoppage of work.
The penalty incurred for violations of permit conditions should not be disproportionate to the
offense committed.

7. Beautifont, Inc. Vs. Court of Appeals

The case of Beautifont, Inc. v. Court of Appeals involves the denial of a preliminary injunction
sought by Rustan Marketing Corp. and Holiday Cosmetics, Inc. to restrain the issuance and
enforcement of a certificate of authority by the Board of Investments in favor of Beautifont, Inc.
and Aura Laboratories, Inc., domestic corporations engaged in the manufacture and
distribution of cosmetic products, due to alleged violations of the Retail Trade Nationalization
Act and the Government's Investment Priorities Plans.
Facts: The case involves the denial of a preliminary injunction sought by Rustan Marketing
Corp. and Holiday Cosmetics, Inc. to restrain the issuance and enforcement of a certificate of
authority by the Board of Investments in favor of Beautifont, Inc. and Aura Laboratories, Inc.
Beautifont, Inc. and Aura Laboratories, Inc. applied with the Board of Investments for authority
to accept investments from two American-owned firms.
The applications stated that Aura and Beautifont were engaged in the cosmetics manufacturing
and distribution business, and that the investments would result in the transfer of stocks from
Philippine nationals to foreign investors.
Rustan Marketing Corporation and Holiday Cosmetics, Inc. opposed the applications, arguing
that they violated the Retail Trade Nationalization Act, posed a monopoly in the cosmetics
industry, were made in an enterprise already exploited by Philippine nationals, were
inconsistent with the Government's Investment Priorities Plans, and would not contribute to the
national economy's development.
The Board of Investments approved the applications, and Rustan and Holiday filed a petition
for certiorari with the Manila Court of First Instance, seeking to invalidate the proceedings
before the Board and requesting a preliminary injunction.
The court denied the motion for injunction, and Rustan and Holiday filed a motion for
reconsideration.
While the motion for reconsideration was pending, Rustan and Holiday filed a petition for
certiorari with the Court of Appeals, seeking to enjoin the enforcement of the certificate of
authority issued by the Board of Investments.
The Court of Appeals granted a temporary restraining order.
Beautifont and Aura filed a petition for certiorari with the Supreme Court, seeking to nullify the
restraining order issued by the Court of Appeals.
The Supreme Court nullified the restraining order and upheld the Board of Investments'
decision to approve the applications.
Issue:
Whether the Board of Investments had acquired jurisdiction over the applications despite the
alleged defective publication and posting of the notice of the applications.
Ruling:
The Supreme Court ruled that the publication and posting of the notice, rather than the
applications themselves, was sufficient to acquire jurisdiction.
The court also held that the Board of Investments did not commit grave abuse of discretion in
approving the applications, as there was no evidence of arbitrary action or serious error.
The court emphasized the strong presumption of correctness accorded to administrative
agencies' acts and determinations and stated that courts should not interfere unless there is a
clear showing of arbitrary action or grave abuse of discretion.
The court concluded that the Board of Investments' decision was based on due notice and
hearing, assessment of the facts, and compliance with relevant legal provisions.
Therefore, the Supreme Court nullified the temporary restraining order and upheld the Board of
Investments' decision to approve the applications of Beautifont, Inc. and Aura Laboratories,
Inc. for permissible investments.
Ratio:
The publication and posting of the notice, rather than the applications themselves, was
sufficient to acquire jurisdiction.
The Board of Investments did not commit grave abuse of discretion in approving the
applications, as there was no evidence of arbitrary action or serious error.
Administrative agencies' acts and determinations are accorded a strong presumption of
correctness, and courts should not interfere unless there is a clear showing of arbitrary action
or grave abuse of discretion.
The Board of Investments' decision was based on due notice and hearing, assessment of the
facts, and compliance with relevant legal provisions.

8. ALMINE VS. COURT OF APPEALS

In the case of Almine v. Court of Appeals, the Supreme Court grants the petitioner's appeal and
sets aside the decision of the Court of Appeals, ruling that the Court of Appeals has jurisdiction
over petitions seeking the extraordinary remedy of certiorari, prohibition, or mandamus in the
transfer of land to tenant-farmers under the Operation Land Transfer Program.
Facts:
Petitioner Hilda Ralla Almine filed a sworn application for retention of her riceland or exemption
from the Operation Land Transfer Program with the Ministry of Agrarian Reform (MAR)
Regional Office in Tabaco, Albay on December 25, 1975.
An investigation report was filed recommending the cancellation of the Certificate of Land
Transfer (CLT) of the private respondent, Sulpicio Bombales, who was the petitioner's tenant.
The Ministry failed to take action, so the petitioner reiterated her application in 1979-1985,
alleging that her tenant deliberately failed to deliver her landowner's share and distributed his
landholding to his children.
Another reinvestigation was conducted, and a report recommending the cancellation of the
private respondent's CLT was filed. The Regional Director and the Officer-in-Charge of MAR
concurred with the report.
However, the Minister of Agrarian Reform denied the petitioner's application for retention in an
order dated February 13, 1986.
The petitioner appealed to the Intermediate Appellate Court (IAC) on April 17, 1986, but the
appeal was dismissed by the Court of Appeals on the ground of lack of jurisdiction.
The petitioner filed a motion for reconsideration, which was denied.
Issue:
Whether the Court of Appeals has jurisdiction over the administrative decision on the transfer
of land to the tenant-farmer under the Operation Land Transfer Program.
Ruling:
The Supreme Court granted the petitioner's appeal and set aside the decision of the Court of
Appeals.
The Court held that the Court of Appeals has concurrent jurisdiction with the Supreme Court
and the Regional Trial Court over petitions seeking the extraordinary remedy of certiorari,
prohibition, or mandamus.
The Court of Appeals erred in holding that it had no jurisdiction over the petition for review by
way of certiorari brought before it.
The case was remanded to the Court of Appeals for further proceedings.
Ratio:
The Court based its decision on Section 9 of the Agrarian Reform Code, which provides that
questions as to whether a landowner should or should not be allowed to retain their
landholdings are exclusively cognizable by the Minister (now Secretary) of Agrarian Reform.
The decision of the Minister may be appealed to the Office of the President and not to the
Court of Agrarian Relations.
These cases are excluded from the jurisdiction of the Court of Agrarian Relations, now the
Regional Trial Courts.
The Court emphasized that the Court of Appeals has concurrent jurisdiction with the Supreme
Court and the Regional Trial Court over petitions seeking the extraordinary remedy of
certiorari, prohibition, or mandamus.
The failure to appeal to the Office of the President from the decision of the Minister of Agrarian
Reform is not a violation of the rule on exhaustion of administrative remedies, as the Minister is
the alter ego of the President.

9. QUALITRANS LIMOUSINE SERVICE, INC. VS. ROYAL CLASS LIMOUSINE SERVICE

The Supreme Court of the Philippines addresses jurisdiction and rights in the case of
Qualitrans Limousine Service, Inc. v. Royal Class Limousine Service, ruling in favor of Royal
Class and upholding their authorization to transport passengers directly from the Manila
International Airport to destinations other than hotels.
Facts:
Qualitrans Limousine Service, Inc. was granted a certificate of public convenience by the
defunct Board of Transportation to operate a "garage (tourist) air-conditioned service" in Manila
to any point in the island of Luzon.
Royal Class Limousine Service acquired the franchise of Transcare, Inc. and obtained a
provisional permit from the Land Transportation Commission to operate a limousine tourist
service for the transportation of outgoing passengers of the Manila International Airport.
Qualitrans filed a motion for reconsideration and a civil case for damages against Royal Class,
claiming that Royal Class was soliciting passengers from the airport to transport them to any
point in Luzon, which was in violation of Qualitrans' business.
Issue:
Whether the Land Transportation Commission had jurisdiction over petitions for declaratory
relief.
Whether the petition for declaratory relief filed by Royal Class was proper.
Whether the decisions of the Land Transportation Commission in previous cases were void for
being contrary to Ministry Order No. 81-054.
Whether the Land Transportation Commission denied Qualitrans due process of law by
advancing the time of the hearing without notice.
Whether the orders of the Land Transportation Commission were supported by evidence.
Whether Royal Class was authorized to transport passengers directly from the Manila
International Airport to destinations other than hotels.
Ruling:
The Court affirms the jurisdiction of the Land Transportation Commission to entertain suits for
declaratory relief, as it falls within its powers and functions to issue, amend, revise, suspend,
or cancel certificates of public convenience.
The Court upholds the propriety of Royal Class' petition for declaratory relief, as it was a
legitimate inquiry into the extent of its rights under its provisional authority.
The Court finds no basis to declare the previous decisions of the Land Transportation
Commission as void, as they were supported by substantial evidence.
The Court rules that Qualitrans was not denied due process, as it had the opportunity to
oppose Royal Class' motion to lift the cease and desist order.
The Court finds that the orders of the Land Transportation Commission were supported by the
evidence presented, including the pending motion for reconsideration and petition for
declaratory relief.
The Court holds that Royal Class is authorized to transport passengers directly from the
Manila International Airport to destinations other than hotels, as it is in the best interests of the
public to have competition in the market.
Ratio:
The Land Transportation Commission has jurisdiction over petitions for declaratory relief
because it falls within its powers and functions to issue, amend, revise, suspend, or cancel
certificates of public convenience.
Royal Class' petition for declaratory relief was proper as it sought to clarify the extent of its
rights under its provisional authority.
The previous decisions of the Land Transportation Commission were not void as they were
supported by substantial evidence.
Qualitrans was not denied due process as it had the opportunity to oppose Royal Class' motion
to lift the cease and desist order.
The orders of the Land Transportation Commission were supported by the evidence
presented, including the pending motion for reconsideration and petition for declaratory relief.
Royal Class is authorized to transport passengers directly from the Manila International Airport
to destinations other than hotels in the best interests of competition in the market.
In conclusion, the Supreme Court affirms the decisions of the lower courts and emphasizes the
importance of competition in the market. Qualitrans' appeals are denied, and the certificate of
public convenience issued to Royal Class is upheld.

10. INDUSTRIAL ENTERPRISES, INC. VS. COURT OF APPEALS

A dispute over a coal operating contract in the Philippines leads to a legal battle between
Industrial Enterprises, Inc. and Marinduque Mining and Industrial Corporation, with the
Supreme Court ultimately upholding the decision of the Court of Appeals based on the doctrine
of primary jurisdiction.
Facts:
Industrial Enterprises, Inc. (IEI) was granted a coal operating contract by the Bureau of Energy
Development (BED) for the exploration of two coal blocks in Eastern Samar.
IEI applied for another coal operating contract for three additional coal blocks, forming the
"Giporlos Area."
IEI was advised that Marinduque Mining and Industrial Corporation (MMIC) should be the
logical coal operator in the area.
An agreement was made for IEI to assign and transfer its rights and interests in the two coal
blocks to MMIC.
IEI filed an action for rescission of the Memorandum of Agreement, alleging that MMIC took
possession of the coal blocks before the agreement was finalized, failed to apply for a coal
operating contract for adjacent blocks, and failed to fulfill payment obligations.
The Philippine National Bank (PNB) was impleaded as a co-defendant due to foreclosure
actions on mortgages held by MMIC.
Issue:
Whether the civil court has jurisdiction to hear and decide the suit for rescission of the
Memorandum of Agreement concerning a coal operating contract over coal blocks.
Whether the Bureau of Energy Development (BED) has jurisdiction over the action instead of
the civil court.

Ruling:
The Court of Appeals held that the Trial Court did not have jurisdiction over the action and that
the BED had jurisdiction.
The Supreme Court upheld this decision based on the doctrine of primary jurisdiction.
Ratio:
The doctrine of primary jurisdiction applies when a claim is within the jurisdiction of the courts
but requires the expertise of an administrative agency.
The determination of coal areas to be exploited and developed falls within the specialized
knowledge of the BED.
The Trial Court does not have the competence to decide matters concerning the exploration,
exploitation, development, and extraction of mineral resources like coal.
The doctrine of primary jurisdiction serves the purpose of ensuring uniformity and consistency
in the regulation of business entrusted to administrative agencies and allows for a more
rational exercise of judicial review.
The application of the doctrine does not dismiss the case but suspends it until the
administrative agency makes its determination.