Syquia vs.

Board of Power

Facts:
Ruiz, Enriquez and Moses filed 3 separate complaints with Board of Power and
Waterworks charging Syquia as administrator of the South Syquia Apartments with the
offense of selling electricity without permit or franchise and alleging that Syquia billed
them for their electricity consumption in excess of the Meralco rates.
In her answer, Syquia questioned the jurisdiction of the Board, saying that she is
not engaged in the sale of electric power but merely passes to the apartment tenants as
the end-users their legitimate electric current bills in accordance with their lease
contracts.

Issue: Whether or not the respondent Board has jurisdiction

Held:

No. Respondent board as a regulatory board manifestly exceeded its jurisdiction

in taking cognizance of and adjudicating the complaints filed by respondents against
petitioner.
Respondent board acquired no jurisdiction over petitioner's contractual relations
with respondents-complainants as her tenants, since petitioner is not engaged in a
public service nor in the sale of electricity without permit or franchise.
Respondents' complaints against being charged he additional cost of electricity
for common facilities used by the tenants (in addition to those registered in their
respective apartment meters) give rise to a question that is purely civil in character that
is to be adjudged under the applicable provisions of the Civil Code (not the Public
Service Act) and not by the respondent regulatory board which has no jurisdiction but by
the regular courts of general jurisdiction.

GLOBE WIRELESS V. PUBLIC SERVICE COMMISSION

Facts:
Private respondent Antonio Arnaiz sent a message to Maria Diaz in Spain
through the telegraph office of the Bureau of Telecommunications in Dumagete and was
transmitted to Manila. The message, however, was not delivered to the addressee. After
being informed of said fact, Arnaiz sent a complaint to the Public Service Commissioner
a letter-complaint. In its answer, petitioner denied liability but questioned PSC’s
jurisdiction over the subject matter. After hearing, the PSC found petitioner responsible
for the unsatisfactory service complained of and ordered it to pay a fine.

Issue: Whether or not respondent PSC has jurisdiction over the matter

Held:

No. The Public Service Act vested in the PSC jurisdiction, supervision and control over
all public services and their franchises, equipment and other properties. However,
Section 5 of RA 4630, the legislative franchise under which petitioner was operating,
limited respondent Commission’s jurisdiction over petitioner only to the rate which
petitioner may charge the public. The negligence imputed to public respondent had
nothing whatsoever to do with the subject matter of very limited jurisdiction of the
Commission over petitioner

PHILIPPINE LAWYER’S ASSOCIATION V. AGRAVA

Facts:
Respondent Director of the Philippine Patent Office issued a circular announcing
an examination schedule for the purpose of determining who are qualified to practice as
patent attorneys before the Philippine Patent Office, the said examination to cover
patent law and jurisprudence and the rules of practice before said office. According to
said circular, members of the Philippine Bar, engineers and other persons with sufficient
scientific and technical training are qualified. Petitioners contend that one who has
passed the bar exams and licensed by the Supreme Court to practice law in the
Philippines is duly qualified to practice before the said office.
On the other hand, respondent Director maintains that the prosecution of patent
cases does not involve entirely the practice of law but includes the application of
scientific and technical knowledge and training.

Issue: Whether or not the appearance before the Philippine Patent Office is included in
the practice of law

Held:
Yes. The practice of law includes such appearance before the Patent Office, the
representation of applicants, oppositors, and other persons, and the prosecution of their
applications for patent, their oppositions thereto or the enforcement of their rights in
patent cases. The practice before the Patent Office involves the interpretation and
application of other laws and legal principles.
Furthermore, the Director of Patents, exercising as he does judicial or quasi-
judicial functions, it is reasonable to hold that a member of the bar, because of his legal
knowledge and training, should be allowed to practice before the said office, without
further examination or other qualification.

GUEVARA V. COMELEC

Facts:
Petitioner published in Sunday Times an article entitled “Ballot Boxes Contract
Hit.” COMELEC then ordered him to show cause why he should not be punished for
contempt for having published said article, which tended to interfere with and influence it
and its members in the adjudication of a controversy then pending investigation and
determination before said body that involves contracts for manufacture and supply
34,000 ballot boxes; and which article likewise tended to degrade, bring into disrepute,
and undermine the exclusive constitutional function of this Commission and its
Chairman.
Petitioner filed a motion to quash and in reply argued that even if COMELEC has
the power to punish contempt, it cannot be applied in this case, where the Commission
is purely administrative function for purchasing ballot boxes.

Issue: Whether or not COMELEC has the power and jurisdiction to conduct contempt
proceedings against Guevara.

HELD: No.
The negotiation conducted by the Commission has resulted in controversy
between several dealers, that however merely refers to a ministerial duty which the
Commission has performed in its administrative capacity. It only discharged a ministerial
duty; it did not exercise any judicial function. Such being the case, it could not exercise
the power to punish for contempt as postulated in the law, for such power is inherently
judicial in nature.
The power to punish contempt is inherent in all courts; its existences is essential
to the preservation of order in judicial proceedings, and to the enforcement of
judgments, orders and mandates of courts, and, consequently, in the administration of
justice.

SEC. OF JUSTICE V. LANTION

Facts:
Secretary of DOJ received a note from US containing a request for the
extradition of private respondent Mark Jimenez to the US. Attached in the note were the
Grand Jury Indictment, the warrant of arrest issued by the US District Court and other
supporting documents for said extradition.
Pending the evaluation of the extradition documents, private respondent wrote a
letter addressed to petitioner requesting copies of the official extradition request.
Petitioner denied the request for the reason that it was still premature to furnish private
respondent with copies of the extradition request pending evaluation by the DOJ.

Private respondent filed a petition for mandamus to compel petitioner to furnish

private respondent the extradition documents. Respondent Judge ruled in favor of
private respondent. Petitioner now questions the decision of the respondent Judge.

ISSUE: Whether or not private respondent is entitled to invoke his due process rights of
notice and hearing during the evaluation stage of the extradition process.

HELD:

Yes. Although the inquisitorial power exercised by the DOJ as an administrative agency
due to the failure of the DFA to comply lacks any judicial discretion, it primarily sets the
wheels for the extradition process which may ultimately result in the deprivation of the
liberty of the prospective extradite. This deprivation can be effected at two stages: (a)
the provisional arrest of the prospective extradite pending the submission of the request
of the prospective extradite pending the submission of the request and (b) the
temporary arrest of the prospective extradite during the pendency of the extradition
petition in court. As such, there is an impending threat to a prospective extradites liberty
as early as during the evaluation stage. Because of these possible consequences, the
evaluation process is akin to an administrative agency conducting an investigative
proceeding, the consequences of which are essentially criminal since such technical
assessment sets off or commences the procedure for, and ultimately, the deprivation of
liberty. The Court has ruled in other cases that where the investigation of an
administrative proceeding may result in forfeiture of life, liberty, or property, the
administrative proceedings are deemed criminal or penal, & such forfeiture partakes the
nature of a penalty. In the case at bar, similar to a preliminary investigation, the
evaluation stage of the extradition proceedings which may result in the filing of an
information against the respondent, can possibly lead to his arrest, & to the deprivation
of his liberty. Thus, the extraditee must be accorded due process rights of notice &
hearing according to A3 §14(1) & (2), as well as A3 §7—the right of the people to
information on matters of public concern & the corollary right to access to official
records & documents.

The basic rights of notice & hearing are applicable in criminal, civil & administrative
proceedings. Non-observance of these rights will invalidate the proceedings. Individuals
are entitled to be notified of any pending case affecting their interests, & upon notice,
may claim the right to appear therein & present their side.

In view of the foregoing premises, the petitioner is ordered to furnish private respondent
copies of the extradition request and its supporting papers, and to grant him a
reasonable period within which to file his comment with supporting evidence.

ANG TIBAY V. CIR

Facts: Teodoro Toribio owns and operates Ang Tibay, a leather company which supplies
the Philippine Army. Due to alleged shortage of leather, Toribio caused the layoff of
mebers of the National Labor Union (NLU). NLU averred that Toribio’s act was not valid.
The CIR decided the case but elevated it to the SC, but a motion for new trial was
raised by the NLU. Ang Tibay filed a motion for opposing the said motion.

ISSUE: What are the requirements in administrative due proceedings?

HELD:
1. Right to a hearing which includes the right of the party interested or affected to
present his own case and submit evidence in support thereof.
2. Tribunal must consider the evidence presented.
3. Tribunal must have something to support the decision
4. The evidence must be substantial.
 5. The decistion must be rendered on the evidence presented at the hearing, or at
least contained in the record and disclosed to the parties affected.
6. The court of CIR or any of its judges must act on its or his own independent
consideration of the law and facts of the controversy, and not simply accept the
views of a subordinate in arriving at a decision.
7. In all controversial questions, CIR must render its decision in such a manner that
the parties to the proceeding can know the various issues involved, and the
reasons for the decision rendered.

MAGCAMIT V. INTERNAL AFFAIRS SERVICE-PHILIPPINE DRUG ENFORCEMENT

AGENCY

Facts:
Magcamit and his co-agents of PDEA were administratively charged with Grave
Misconduct after allegations that they received money in exchange for the release of
one Luciana Jaen after she was apprehended in a buy-bust operation in Lipa City.

Magcamit filed his motion for reconsideration arguing that the IAS-PDEA
committed errors of law and/or irregularities prejudicial to his interest; its decision, too,
was not supported by the evidence on record. The board denied the motion for
reconsideration on the ground that petitioner and his co-agents had been duly afforded
administrative due process and had been given a fair and reasonable opportunity to
explain their side.

Magcamit elevated the case to the CSC and CA but denied such petition.

Issue: What are the cardinal rights and principles of administrative agencies?

Held/ Doctrine:

The Cardinal Rights and principles of the requisites of administrative due process
explained:

The 1st of the enumerated rights pertains to the substantive rights of a party at the
hearing stage. The 2nd to 6th are reinforcements of the right to a hearing and the
inviolable rights applicable at the deliberative stage, as the decision maker decides on
the evidence presented during the hearing. These standards set forth are material and
substantial components of decision-making. Finally, the last requirement, relating to the
form and substance of the decision of a quasi-judicial body is in conformity with
substance to the constitutional requirement that a decision of a court must state
distinctly the facts and the law upon which it is based.

(The court ruled in favor of Magcamit but due to lack of substantial evidence)