Admin Case Digests (Part 1)

Luzon Development Bank vs Association of LDB Employees 249 SCRA 162

From a submission agreement of the LDB and the Association of Luzon Development Bank Bank Employ Employees ees (ALDBE (ALDBE)) arose arose an arbitr arbitrati ation on case case to resolv resolve e the follo folloing ing issue! issue! "heth "hether er or not not the the comp compan any y has has viol violat ated ed the the #BA #BA prov provis isio ion n and and the the $%A $%A on promotion& At a conference' the parties agreed on the submission of their respective osition apers& Atty& arcia' in her capacity as *oluntary Arbitrator' received ALDBE+s osition aper , LDB' on the other hand' failed to submit its osition aper despite a letter from the *oluntary Arbitrator reminding them to do so& As of $ay -.' /001 no osition aper had been 2led by LDB& "ithout LDB+s osition aper' the *oluntary Arbitrator rendered a decision disposing as follos! WHEREFORE, fnding is hereby made that the Bank has not adhered to the CBA  pro  provision ion nor nor the MOA on promotio otion n.

3ence' this petition for certiorari and prohibition seeking to set aside the decision of the *oluntary Arbitrator and to prohibit her from enforcing the same& 4556E! "%7 a voluntary arbiter+s decision is appealable to the #A and not the 5# 3ELD! 8E5' the 9urisdiction conferred conferred by la on a voluntary arbitrator or a panel of such arbitrators arbitrators is :uite limited compared compared to the original 9urisdiction 9urisdiction of the labor arbiter and the appellate 9urisdiction of the 7L;# for that matter&  ecutory unless appealed to the #ommission ?@ 3ence' hile there is an e>press mode of appeal from the decision of a labor arbiter' ;epublic Act 7o& /1 is silent ith respect to an appeal from the decision of a voluntary arbitrator&  8et'  8et' past practice shos that a decision or aard of a voluntary voluntary arbitrator is' more often than not' elevated to the 5# itself on a petition for certiorari' in eCect e:uating the voluntary arbitrator ith the 7L;# or the #A& 4n the vie of the #ourt' this is illogical and imposes an unnecessary burden upon it&

R!" A"D S#EEL A$#%!R#&' petitione(' vs)#%E C!$R# !* A++EALS an, -ARA CRS#"A *ER#L.ER C!R+!RA#!"' (espon,ents)

Facts! pansion in 4ligan #ity that as occupied by chemical fertilizer plants of $#F#& propriation case against $#F# for the land in the ;<# in 4ligan& "hile the case as on going' the statutory e>istence of 45A ceased (D -and E% 111 only e>tended the term of 45A until /00)& $#F# 2led for dismissal because there as no longer a plaintiC since 45A as ine>istent and ;<# granted it& 45A appealed and ;<# said that the overnment couldn+t replace them and so the case should be dismissed& ;<# also said that since the 45A as e>propriating for 75A it asn+t for public bene2t and not the right use of eminent domain& 45A appealed to #A and #A said that the case as dismissed but the government could 2le a case for eminent domain because it as for public bene2t seeing as the 75A as a government subsidiary& Appeal ent up to the 5#& 4ssue! "hether or not the overnment could replace 45A in the 9udicial proceedings 3eld! 8es' ursuant to ;ules of #ourt' the parties of a case can either be natural or 9uridical persons& ist in a pending case& propriation case hadn+t actually been heard on its merits& LA5
Soli, %omes' nc) vs) +aya/al' 100 SCRA 02' 09 1993

FA#<5! ecuted a deed of sale over the land but failed to deliver the corresponding certi2cate of title because it as later discovered that 5olid 3omes had mortgaged the property in bad faith to a 2nancing company& emplary damages' attorneyMs fees and the costs of the suit& 5olid 3omes moved to dismiss the complaint on the ground that the court had no 9urisdiction' this being vested in the 7ational 3ousing Authority under D 7o& 01& 4556E! "%7 the 7ational 3ousing Authority has the 9urisdiction to decide the case& 3ELD! 8es& ecution in the Enforcement of 4ts Decisions 6nder residential Decree 7o& 01&N 5E#<4%7 /& 4n the e>ercise of its function to regulate the real estate trade and shall have e>clusive 9urisdiction to hear and decide cases of the folloing nature! A& 6nsound real estate business practices, B& #laims involving refund and any other claims 2led by subdivision lot or condominium unit buyer against the pro9ect oner' developer' dealer' broker or salesman, and #& #ases involving speci2c performance of contractual statutory obligations 2led by buyers of subdivision lot or condominium unit against the oner' developer' dealer' broker or salesman&  ity of the modern society' it has become necessary to create more and more administrative bodies to help in the regulation of its rami2ed activities& 5pecialized in the particular 2elds assigned to them' they can deal ith the problems thereof ith more e>pertise and dispatch than can be e>pected from the legislature or the courts of 9ustice&
increasing vesture of :uasilegislative and :uasi9udicial poers in hat is no not unreasonably called the fourth department of the government&

CA vs 5nacio )R) "o) 16409 he e!tent to "hi#h an administrative entity may e!er#ise $%di#ia& or '%asi(  $%di#ia& po"ers depends &arge&y, i) not "ho&&y on the provisions o) the stat%te #reating or empo"ering s%#h agen#y. *n the e!er#ise o) s%#h po"ers, the agen#y #on#erned m%st #ommon&y interpret and app&y #ontra#ts and determine the rights o) private parties %nder s%#h #ontra#ts. One thr%st o)  the m%&tip&i#ation o) administrative agen#ies is that the interpretation o)  #ontra#ts and the determination o) private rights there%nder is no &onger a %ni'%e&y $%di#ia& )%n#tion, e!er#isab&e on&y by o%r reg%&ar #o%rts.

FA#<5! #A entered into a #ontract to 5ell a subdivision lot (sub9ect property) ith the respondents the registered oners and developers of a housing subdivision knon as *illa riscilla 5ubdivision located in Bulacan& 6nder the #ontract to 5ell' #A ould pay -'..'KKK&KK for the sub9ect property on installment basis, they ere to pay a don payment of  /'/H'1KK' ith the balance payable ithin three years& 5ubse:uently' the parties mutually agreed to amend the #ontract to 5ell to e>tend the payment period from three to 2ve years& According to #A' it religiously paid the monthly installments until its administrative pastor discovered that the title covering the sub9ect property as actually part of to consolidated lots (Lots -F and - BsdKKKKH-0 P%Lemplary damages' attorneys fees and litigation e>penses& 4nstead of 2ling an anser' the respondents 2led a motion to dismiss asserting that the ;<# had no 9urisdiction over the case& clusive 9urisdiction of the 3L6;B since it involved the sale of a subdivision lot& #A opposed the motion to dismiss' claiming that the action is for rescission of contract' not speci2c

performance' and is not among the actions ithin the e>clusive 9urisdiction of the 3L6;B& 4556E! "hich of the to the regular court or the 3L6;B has e>clusive  9urisdiction over #As action for rescission and damages& 3ELD! 3L6;B has e>clusive 9urisdiction over #As action for rescission and damages& ;ationale for 3L6;Bs e>tensive :uasi9udicial poers tent of the 3L6;Bs e>clusive 9urisdiction& clusive 9urisdiction over complaints arising from contracts beteen the subdivision developer and the lot buyer or those aimed at compelling the subdivision developer to comply ith its contractual and statutory obligations to make the subdivision a better place to live in& enerally' the e>tent to hich an administrative agency may e>ercise its poers depends largely' if not holly' on the provisions of the statute creating or empoering such agency& residential Decree (&D&) 7o& /.' NEmpoering the 7ational 3ousing Authority to 4ssue "rit of E>ecution in the Enforcement of its Decision under residential Decree 7o& 01'N clari2es and spells out the :uasi9udicial dimensions of the grant of 9urisdiction to the 3L6;B& ercise of that prerogative should be brought to the 3L6;B hich has the technical knoho on the matter& 4n the e>ercise of its poers' the 3L6;B must commonly interpret and apply contracts and determine the rights of  private parties under such contracts& ercisable only by the regular courts& ercised by them as an incident of the principal poer entrusted to them of regulating certain activities falling under their particular e>pertise& 4n this era of clogged court dockets' the need for specialized administrative boards or commissions ith the special knoledge' e>perience and capability to hear and determine promptly

disputes on technical matters or essentially factual matters' sub9ect to  9udicial revie in case of grave abuse of discretion' has become ellnigh indispensable& 4n general' the :uantum of 9udicial or :uasi9udicial poers hich an administrative agency may e>ercise is de2ned in the enabling act of such agency& 4n other ords' the e>tent to hich an administrative entity may e>ercise such poers depends largely' if not holly on the provisions of  the statute creating or empoering such agency& 4n the e>ercise of such poers' the agency concerned must commonly interpret and apply contracts and determine the rights of private parties under such contracts& %ne thrust of the multiplication of administrative agencies is that the interpretation of  contracts and the determination of private rights thereunder is no longer a uni:uely 9udicial function' e>ercisable only by our regular courts&

Da,uo v) Civil Se(vice Commission

Facts! Dadubo and #idro of the DB Borongan branch bank ere administratively charged ith conduct pre9udicial to best interest of the service' based on allegations on the unposted ithdraal of K'KKK from the savings accounts of the
Lian5a Bay Lo55in5' Co)' nc) v) Ena5e' )R) "o) L78680' :uly 16' 190

Facts! pertise unless there is a clear shoing that the latter acted arbitrarily or ith grave abuse of 

discretion or hen they have acted in a capricious and himsical manner such that their action may amount to an e>cess or lack of 9urisdiction&