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Manila Public School Teachers Association vs.

Laguio 200 SCRA 232 (1991) Facts: The series of events that touched off these cases started with the so-called " ass action" underta!en "# so e $00 %u"lic school teachers& a on' the e "ers of the %etitionin' associations in "oth cases& on Se%te "er 1(& 1990 to "dra ati)e and hi'hli'ht" 1 the teachers* %li'ht resultin' fro the alle'ed failure of the %u"lic authorities to act u%on 'rievances that had ti e and a'ain "een "rou'ht to the latter*s attention+ Issue: Are e %lo#ees in the %u"lic service %rohi"ited fro for in' unions and holdin' stri!es,

Held: -These . ass actions/ were to all intents and %ur%oses a stri!e0 the# constituted a concerted and unauthori)ed sto%%a'e of& or a"sence fro & wor! which it was the teachers/ dut# to %erfor & underta!en for essentiall# econo ic reasons&1 should not %rinci%all# resolve the %resent case& as the underl#in' facts are alle'edl# not identical+ (htt%233!arissafa#e+"lo's%ot+co 320093123di'ests-article-iii-sections-4-$+ht l)

Antique Sawmills Inc. vs. a!co 1( SCRA 315

Facts: A %u"lic "iddin' was conducted for the award of a 125$0-hectare forest area+ Anti6ue Saw ills& 7nc+& and A6uiles 8a#co su" itted their "id a%%lications with the 9ureau of :orestr#+ The "id was awarded to A6uiles R+ 8a#co+ ;owever& on otion for reconsideration& the Secretar# of A'ricultural and <atural Resources issued an order awardin' in e6ual %ortion the forest area in 6uestion& to A6uiles R+ 8a#co and Anti6ue Saw ills& 7nc+ 8a#co oved to reconsider the said decision however the sa e was dis issed for havin' "een alle'edl# filed outside the re'le entar# %eriod %rescri"ed in Section 10 of :orestr# Ad inistrative =rder <o+ 52 for the %erfection of a%%eal+ 8a#co a%%ealed to the =ffice of the >resident aintainin' that the said %eriod is a ere %rocedural technicalit# which& at least in ad inistrative %roceedin's& a# li"erall# "e rela?ed+ Anti6ue Saw ills& 7nc+ inter%osed an o%%osition contendin' that the =ffice of the >resident has no @urisdiction to review on a%%eal a decision of the Secretar# of A'riculture and <atural Resources which has "eco e final+ 8a#co& on the other hand aintains that the %eriod fi?ed in Ad inistrative =rder <o+ 5-2 of the Airector of :orestr# cannot "ind the =ffice of the >resident since the latter has su%ervision and control over the for er+ Issue: Bhether or not the %eriod for the %erfection of a%%eal is andator#+

Bhether or not the =ffice of the >resident still retains or %ossesses @urisdiction to review on a%%eal a decision of the Secretar# of A'riculture and <atural Resources which has "eco e final+ Held: Co %liance with the %eriod %rovided "# law for the %erfection of an a%%eal is not erel# andator# "ut also a @urisdictional re6uire ent+ Such failure has the effect of renderin' final the @ud' ent of the court& and the certification of the record on a%%eal thereafter cannot restore the @urisdiction which has "een lost+ That ad inistrative rules and re'ulations have the force of law can no lon'er "e 6uestioned+ 8a#co/s view that the %eriod fi?ed in Ad inistrative =rder <o+ 5-2 of the Airector of :orestr# cannot "ind the =ffice of the >resident since the latter has su%ervision and control over the for er cannot co end itself to sound %u"lic %olic#+ Cven ad inistrative decisions ust and so eti e& as full# as %u"lic %olic# de ands that finalit# "e written on @udicial controversies+ 7n other words& %u"lic interest re6uires that %roceedin's alread# ter inated should not "e altered at ever# ste%+ The rule of non quieta movere %rescri"es that what was alread# ter inated should not "e distur"ed+

Industrial "nter#rises Inc. vs. $A 1$D SCRA D25

Facts: 7ndustrial Cnter%rises 7nc+ (7C7) was 'ranted a coal o%eratin' contract "# the Eovern ent throu'h the 9ureau of Cner'# Aevelo% ent (9CA) for the e?%loration of two coal "loc!s in Castern Sa ar+ 7C7 was later on advised that in line with the o"@ective of rationali)in' the countr#*s over-all coal su%%l#-de and "alance + + + the lo'ical coal o%erator in the area should "e the Farindu6ue Finin' and 7ndustrial Cor%oration (FF7C)& which was alread# develo%in' the coal de%osit in another area (9a'aca# Area) and that the 9a'aca# and Ei%orlos Areas should "e awarded to FF7C+ Thus& 7C7 and FF7C e?ecuted a Fe orandu of A'ree ent where"# 7C7 assi'ned and transferred to FF7C all its ri'hts and interests in the two coal "loc!s which are the su"@ect of 7C7*s coal o%eratin' contract+ Su"se6uentl#& however& 7C7 filed an action for rescission of the Fe orandu of A'ree ent with da a'es a'ainst FF7C and the then Finister of Cner'# "efore the Re'ional Trial Court of Fa!ati& for "reach of a'ree ent+ 7n a su ar# @ud' ent& the Trial Court ordered the rescission of the Fe orandu of A'ree ent+ 7n reversin' the Trial Court& the Court of A%%eals held that the rendition of the su ar# @ud' ent was not %ro%er since there were 'enuine issues in controvers# "etween the %arties& and ore i %ortantl#& that the Trial Court had no @urisdiction over the action considerin' that& under >residential Aecree <o+ 1205& it is the 9CA that has the %ower to decide controversies relative to the e?%loration& e?%loitation and develo% ent of coal "loc!s+ Issue: Bhether or not res%ondent Court of A%%eals erred in holdin' that it is the 9ureau of Cner'# Aevelo% ent (9CA) which has @urisdiction over said action for rescission of the Fe orandu of A'ree ent concernin' a coal o%eratin' contract over coal "loc!s and not the civil court+ Held: 7n recent #ears& it has "een the @uris%rudential trend to a%%l# the doctrine of %ri ar# @urisdiction in an# cases involvin' atters that de and the s%ecial co %etence of ad inistrative a'encies+ 7t a# occur that the Court has @urisdiction to ta!e co'ni)ance of a %articular case& which eans that the atter involved is also @udicial in character+ ;owever& if the case is such that its deter ination re6uires the e?%ertise& s%eciali)ed s!ills and !nowled'e of the %ro%er ad inistrative "odies "ecause technical atters or intricate 6uestions of facts are involved& then relief ust first "e o"tained in an ad inistrative %roceedin' "efore a re ed# will "e su%%lied "# the courts even thou'h the atter is within the %ro%er @urisdiction of a court+ Clearl#& the doctrine of %ri ar# @urisdiction finds a%%lication in this case since the 6uestion of what coal areas should "e e?%loited and develo%ed and which entit# should "e 'ranted coal o%eratin' contracts over said areas involves a technical deter ination "# the 9CA as the ad inistrative a'enc# in %ossession of the s%eciali)ed e?%ertise to act on the atter+ The Trial Court does not have the co %etence to decide atters concernin' activities relative to the e?%loration& e?%loitation& develo% ent and e?traction of ineral resources li!e coal+ These issues %reclude an initial @udicial deter ination+ 7t "ehoves the courts to stand aside even when a%%arentl# the# have statutor# %ower to %roceed in reco'nition of the %ri ar# @urisdiction of an ad inistrative a'enc#+ The a%%lication of the doctrine of %ri ar# @urisdiction& however& does not call for the dis issal of the case "elow+ 7t need onl# "e sus%ended until after the atters within the co %etence of the 9CA are threshed out and deter ined+ There"#& the %rinci%al %ur%ose "ehind the doctrine of %ri ar# @urisdiction is salutaril# served+ I#e%di&an Merchandising $o. vs. $TA 9 SCRA (2

Facts: The Co issioner of 7nternal Revenue assessed fro 7%e!d@ian >9(& 402+24 as co %ensatin' ta? and surchar'e on 'old chains i %orted "# it& which were later converted into 'old "ullion& %lus >200 co %ro ise %enalt#+ 7%e!d@ian a%%ealed to 9oard of Ta? A%%eals+ The 9oard of Ta? A%%eals affir ed the Co issioner/s @ud' ent+ 7%e!d@ian a%%ealed to Su%re e Court "ut the latter dis issed the sa e+ 7%e!d@ian sou'ht to reinstate its a%%eal with Su%re e Court "ut was denied+ 7%e!d@ian sou'ht to reo%en the case with CTA+ CTA dis issed+ Fotion for Reconsideration was also denied+ 7%e!d@ian ade %artial %a# ent& "ut later it filed with the Co issioner a clai for refund of the sa e+ This was denied+ 7%e!d@ian filed %etition for review in CTA+ Co issioner filed his answer in the CTA case& raisin' the affir ative defense of res @udicata+ Fotion for e?ecution of @ud' ent in 9TA case was 'ranted "# CTA0 hence this %etition for certiorari+ 7%e!d@ian ar'ues that res @udicata a%%lies onl# to @ud' ent of courts& not to decisions of ad inistrative a'encies+ Issue: Bhether or not res @udicata a%%lies to decisions of ad inistrative a'encies+ Held: GCS+ The re6uisites for res @udicata are2 a+ final for er @ud' ent "+ court has @urisdiction over su"@ect atter and %arties c+ @ud' ent on erits d+ "etween first and second actions e+ identit# of %arties- identit# of su"@ect atter f+ identit# of cause of action The ore e6uita"le attitude is to allow e?tension of defense to decisions of "odies u%on which @udicial %owers have "een conferred+ 7n "oth cases& issue is the sa e2 B=< a%%ellant is lia"le for co %ensatin' ta?+

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