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SCRA 162
From a submission agreement of the LDB and the Association of Luzon Development
Bank Employees (ALDBE) arose an arbitration case to resolve the following issue:
Whether or not the company has violated the CBA provision and the MOA on
promotion.
At a conference, the parties agreed on the submission of their respective Position
Papers. Atty. Garcia, in her capacity as Voluntary Arbitrator, received ALDBEs Position
Paper ; LDB, on the other hand, failed to submit its Position Paper despite a letter from
the Voluntary Arbitrator reminding them to do so. As of May 23, 1995 no Position Paper
had been filed by LDB.
Without LDBs Position Paper, the Voluntary Arbitrator rendered a decision disposing as
follows:
WHEREFORE, finding is hereby made that the Bank has not adhered to the CBA
provision nor the MOA on promotion.
Hence, this petition for certiorari and prohibition seeking to set aside the decision of the
Voluntary Arbitrator and to prohibit her from enforcing the same.
ISSUE: WON a voluntary arbiters decision is appealable to the CA and not the SC
HELD: YES, the jurisdiction conferred by law on a voluntary arbitrator or a
panel of such arbitrators is quite limited compared to the original jurisdiction
of the labor arbiter and the appellate jurisdiction of the NLRC for that matter.
The (d)ecision, awards, or orders of the Labor Arbiter are final and
executory unless appealed to the Commission Hence, while there is an
express mode of appeal from the decision of a labor arbiter, Republic Act No.
6715 is silent with respect to an appeal from the decision of a voluntary
arbitrator.
Yet, past practice shows that a decision or award of a voluntary arbitrator is,
more often than not, elevated to the SC itself on a petition for certiorari, in
effect equating the voluntary arbitrator with the NLRC or the CA. In the view
of the Court, this is illogical and imposes an unnecessary burden upon it.
performance, and is not among the actions within the exclusive jurisdiction
of the HLURB.
ISSUE: Which of the two the regular court or the HLURB has exclusive
jurisdiction over CGAs action for rescission and damages.
HELD: HLURB has exclusive jurisdiction over CGAs action for rescission and
damages.
Rationale for HLURBs extensive quasi-judicial powers The surge in the real
estate business in the country brought with it an increasing number of cases
between subdivision owners/developers and lot buyers on the issue of the
extent of the HLURBs exclusive jurisdiction. The courts have consistently
ruled that the HLURB has exclusive jurisdiction over complaints arising from
contracts between the subdivision developer and the lot buyer or those
aimed at compelling the subdivision developer to comply with its contractual
and statutory obligations to make the subdivision a better place to live in.
Generally, the extent to which an administrative agency may exercise its
powers depends largely, if not wholly, on the provisions of the statute
creating or empowering such agency. Presidential Decree (P.D.) No. 1344,
"Empowering the National Housing Authority to Issue Writ of Execution in the
Enforcement of its Decision under Presidential Decree No. 957," clarifies and
spells out the quasi-judicial dimensions of the grant of jurisdiction to the
HLURB. The provisions of PD 957 were intended to encompass all questions
regarding subdivisions and condominiums. The intention was aimed at
providing for an appropriate government agency, the HLURB, to which all
parties aggrieved in the implementation of provisions and the enforcement
of contractual rights with respect to said category of real estate may take
recourse. The business of developing subdivisions and corporations being
imbued with public interest and welfare, any question arising from the
exercise of that prerogative should be brought to the HLURB which has the
technical know-how on the matter. In the exercise of its powers, the HLURB
must commonly interpret and apply contracts and determine the rights of
private parties under such contracts. This ancillary power is no longer a
uniquely judicial function, exercisable only by the regular courts. The
argument that only courts of justice can adjudicate claims resoluble under
the provisions of the Civil Code is out of step with the fast-changing times.
There are hundreds of administrative bodies now performing this function by
virtue of a valid authorization from the legislature. This quasi-judicial
function, as it is called, is exercised by them as an incident of the principal
power entrusted to them of regulating certain activities falling under their
particular expertise. In this era of clogged court dockets, the need for
specialized administrative boards or commissions with the special
knowledge, experience and capability to hear and determine promptly
Lianga Bay Logging, Co., Inc. v. Enage, G.R. No. L-30637, July 16,
1987
Facts: The parties are both forest concessionaries whose licensed areas are
adjacent to each other. Since the concessions of petitioner and respondent
are adjacent to each other, they have a common boundary. Reports of
encroachment by both parties on each others concessions triggered a
survey to establish the common boundary of the respective concession areas
and was held that the claim of Ago Timber Corporation runs counter to the
intentions of the Office granting the Timber License Agreement to Lianga Bay
Logging. Ago Timber appealed to Department of Agriculture and Natural
Resources and set aside the appealed decision of the Director of Forestry and
ruled in favor of Ago. Lianga Bay Logging elevated the case to office of
President and ruling of Agriculture and Natural Resources was affirmed. On
Motion for Recon, decision was reversed and reinstated decision of Director
of Forestry. A civil action was instituted by Ago Timber to determine the
correct boundary line of license timber areas. TRO was set in place. Lianga
brought the case to SC on certiorari.
Issue: WON respondent court has jurisdiction over the administrative case
Held: Respondent Judge erred in taking cognizance of the complaint filed by
respondent Ago, asking for the determination anew of the correct boundary
line of its licensed timber area, for the same issue had already been
determined by the Director of Forestry, the Secretary of Agriculture and
Natural Resources and the Office of the President, administrative officials
under whose jurisdictions the matter properly belongs. Section 1816 of the
Revised Administrative Code vests in the Bureau of Forestry, the jurisdiction
and authority over the demarcation, protection, management, reproduction,
reforestation, occupancy, and use of all public forests and forest reserves
and over the granting of licenses for game and fish, and for the taking of
forest products, including stone and earth therefrom. The Secretary of
Agriculture and Natural Resources, as department head, may repeal or
modify the decision of the Director of Forestry when advisable in the public
interests, whose decision is in turn appealable to the Office of the President.
For the respondent court to consider and weigh again the evidence already
presented and passed upon by said officials would be to allow it to substitute
its judgment for that of said officials who are in a better position to consider
and weigh the same in the light of the authority specifically vested in them
by law. it is a well-settled doctrine that the courts of justice will generally not
interfere with purely administrative matters which are addressed to the
sound discretion of government agencies and their expertise unless there is
a clear showing that the latter acted arbitrarily or with grave abuse of