Vidad v. RTC of Negros Oriental, Br.

42
October 18, 1993 | Vitug, J. | Special Civil Actions of Certiorari, Prohibition and
Mandamus | Primary Jurisdiction or Preliminary Resort
SUMMARY: A Group of public school teachers held a strike. The RD issued a
return to work order, with a warning of administrative charges for failure to comply.
The order went unheeded, hence, the teachers were charged administratively. They
filed a complaint for injunction, prohibition and damages before the RTC, which
granted a TRO, prohibiting the DECS Officials from continuing with the
administrative investigation. Defendants filed an MD, while the Plaintiffs moved to
declare defendants in default. Both motions were denied. SC ruled that the lower
court erred in issuing the TROs, citing the doctrine of primary jurisdiction, and
ordered that it suspend further proceedings until final determination on the
administrative proceedings have been made.
DOCTRINE: The doctrine of primary jurisdiction does not warrant a court to
arrogate unto itself the authority to resolve a controversy the jurisdiction over which
is initially lodged with an administrative body of special competence.
FACTS:
1. A group of public school teachers in Negros Oriental held a mass action from
Sept 19-21, 1990, to demand the release of their salaries by the Department of
Budget, as well as to assail the alleged corruption in DECS. RD Teofilo Gomez
issued a return-to-work order, with a warning that those who fail to do so within
24 hrs would be facing administrative charges, which went unheeded. As such,
admin complaints were filed, and the teacher were given 5 days from receipt of
the complaints within which to submit their answers and supporting documents.
An investigation panel was constituted.
2. Said teachers filed with the RTC of Dumaguete a complaint for injunction,
prohibition and damages, with a prayer for preliminary injunction against the
DECS officials which constituted the investigation panel, which was granted by
the court. Defendants filed their Answer, followed by an MD. The school
teachers, on the other hand, moved to strike out the appearance of the OSG and to
declare the defendants in default (They contend that the defendants are being
sued solely in their private capacity, as such the SolGen may not represent them).
Both motions were denied. From said denial, both parties filed the respective
petitions, which were consolidated, along with 4 other cases raising like issues.
3. Public school teachers: Defendants, illegally withheld their salaries, wrongfully
filed administrative charges against them, unjustifiably refused to inform them of
the nature and cause of accusation upon which the charges were initiated,
inexcusably violated elemental due process, and erroneously applied the law.
They also pray for actual and moral damages, plus attorneys fees, as well as for
an order restraining the defendants from further proceeding with the
administrative investigations.
ISSUE/S:

1.
2.

WoN the OSG may properly represent the defendants in the RTC cases
WoN the RTC should have dismissed outright the cases

HELD/RULING: DISMISSED.
RATIO:
1. The plaintiffs contention that the defendants are being sued only in their private
capacity is not borne by their allegations and prayers. In fact, the root of the cases
filed deal with the performance of official functions by the DECS Officials. WoN
such were proper or improper, or WoN they acted in good faith or bad faith,
cannot yet be determined, pending a full hearing that would afford all parties an
opportunity to ventilate their respective contentions. As such, it must be
presumed that official duties have been regularly performed.
2. The SolGen did not act improperly in deciding to represent the DECS Officials in
the above cases. PD 487 and the Administrative Code of 1987 provide that the
OSG shall represent the Government in the SC and the CA in all criminal
proceedings; represent the Government and its officers in the SC, the CA, and all
other courts or tribunals in all civil actions and special proceedings in which the
Government or any officer thereof in his official capacity is a party.
3. The various complaints filed by the public school teachers allege bad faith on the
part of the DECS officials. Assuming that plaintiffs are able to establish their
allegations of bad faith, a judgment for damages can be warranted. In such a case,
the public officials may not be said to have acted within the scope of their official
authority; thus, they are no longer protected by the mantle of immunity for
official actions, and may be held liable for damages in their personal capacities.
4. Nonetheless, it was inopportune for the lower court to issue restraining orders.
The authority of the DECS RD to issue the return to work order and to initiate the
administrative charges and to constitute the investigating panel can hardly be
disputed.
5. The SC stated that the civil cases and the administrative cases were closely
interrelated. While no prejudicial question strictly arises where one is a civil case
and the other is an administrative proceeding, in the interest of good order, it
behooves the court to suspend its action on the cases before it pending the final
outcome of the administrative proceedings. The doctrine of primary jurisdiction
does not warrant a court to arrogate unto itself the authority to resolve a
controversy the jurisdiction over which is initially lodged with an administrative
body of special competence.
Note: The Court stated in this case that the civil cases against the DECS Officials
prescinded from the administrative actions taken, or yet to be taken, against the
public school teachers. Since both matters are interlinked, even though the SC itself
pronounced that there is no prejudicial question, it resolved to suspend the case until
the final disposition of the administrative case.