PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT, petitioner, vs.

HON. EMMANUEL G. PEÑA, as Presiding Judge, RTC, NCJR, Br. CLII, Pasig, Metropolitan
Manila, and YEUNG CHUN KAM, YEUNG CHUM HO and ARCHIE CHAN represented by
YIM KAM SHING, respondents.
G.R. No. 77663 April 12, 1988

Facts:

PCGG (Commission) ordered the freezing of the assets and records of 2 export garment
corporations. The Commission appointed Noemi Saludo as Officer-in-Charge and one of the
authorized signatories of the funds of the two corporations. Saludo sent a memorandum
addressed to the depositary banks wherein she revoked the authorizations previously issued,
finding that the other authorized signatory, Yim Kam Shing, was a Hongkong Chinese national
staying in the country as mere tourist.

The foreign investors instituted through Yim Kam Shing an action against the Commission and
its Commissioner questioning the revocation of the authorization as signatory granted to Yim
Kam Shing. RTC issued a cease and desist order to PCGG.

Issue: Whether the RTC has jurisdiction over the case.

Held:
RTC has no jurisdiction over the case. The Supreme Court held that the cease and desist order
is null and void.

Section 2 of Executive Order 14 provides that that "The Presidential Commission on Good
Government shall file all such cases, whether civil or criminal, with the Sandiganbayan which
shall have exclusive and original jurisdiction thereof." Necessarily, those who wish to question or
challenge the Commission's acts or orders in such cases must seek recourse in the same court,
the Sandiganbayan, which is vested with exclusive and original jurisdiction. The
Sandiganbayan's decisions and final orders are in turn subject to review on certiorari exclusively
by this Court.

In the exercise of quasi-judicial functions, the Commission is a co-equal body with regional trial
courts and "co-equal bodies have no power to control the other." The Solicitor General correctly
submits that the lack of jurisdiction of regional trial courts over quasi-judicial agencies is
recognized in section 9, paragraph 3 of Batas Pambansa Blg. 129 (the Judiciary Reorganization
Act of 1980), which otherwise vests exclusive appellate jurisdiction in the Court of Appeals over
all final judgment, decisions, resolutions, orders, or awards of regional trial courts and quasi
judicial agencies, instrumentalities, boards or commissions.

Executive Order No. 1 effectively withholds jurisdiction over cases against the Commission from
all lower courts, including the Court of Appeals, except the Sandiganbayan in whom is vested
original and exclusive jurisdiction and this Court. Early on, in special civil actions questioning
challenged acts of the Commission, its submittal that the cited Executive Order bars such
actions in this Court was given short shrift because this Court, as the third great department of
government vested with the judicial power and as the guardian of the Constitution, cannot be
deprived of its certiorari jurisdiction to pass upon and determine alleged violations of the
citizens' constitutional and legal rights under the Rule of Law.
MAGNO MANUEL, plaintiff-appellant, vs. MARIANO VILLENA, THE DIRECTOR OF
FORESTRY, THE SECRETARY OF DEPARTMENT OF AGRICULTURE AND NATURAL
RESOURCES, defendants-appellees.
1971 Feb 27 G.R. No. L-28218

Facts:
Manuel has been in continuous possession of the land in question since 1939. Being an
ignorant farmer he did not file his Tree Farm application (No. 13312) until June 1954. When he
filed an application, the Director of Forestry rejected the same because a prior application (No.
3852) had been filed by Mariano Villena in November 1955. His appeal to the Secretary of
Agriculture and National Resources (ANR) was dismissed. Manuel filed a complaint before the
lower court. The complaint was later amended, stating that the investigation made by the
Department of ANR was not completed and was not in accordance with the due process of law,
and that the Secretary of ANR rendered a decision, with grave abuse of discretion, dismissing
the appeal of Manuel.

Villena moved the dismissal of the amended complaint on the ground that it did not cure the
defects of the original one, and still contained sufficient allegations to make out a cause of
action or to confer jurisdiction upon the court to set aside or annul the administrative decision
complained of. The lower court ordered the dismissal of the case – the Director of Forestry and
Secretary of ARN did not commit grave abuse of discretion.

Issue: Whether the lower court has jurisdiction over the case.

Held:
Yes, the lower court has jurisdiction over the case. The Supreme Court affirmed the order to
the lower court.

Section 1838 of the Revised Administrative Code provides:

SECTION 1838. Leasing of forest land for special purposes. The Director of Forestry
with the approval of the Secretary of Agriculture and Natural Resources, may, upon such terms
as he may deem reasonable, lease or grant go any Filipino citizen or association of persons
duly incorporated and authorized by the Constitution to acquire lands of the public domain,
permits for the use of forest lands or vacant public lands not declared agricultural land for a
period not exceeding twenty-five years, for the establishment of sawmills, lumber yards, timber
depots, logging camps, rights-of-way and plantations for the raising of nipa and/or other palms,
bacauan, medicinal plants or trees of economic value . . ."

The power conferred on the Director of Forestry with the approval of the Secretary of Agriculture
and Natural Resources is basically executive or administrative in nature. And courts, as a rule,
refuse to interfere with proceedings undertaken by administrative bodies or officials in the
exercise of administrative functions. This is so because such bodies are generally better
equipped technically to decide administrative questions and that non-legal factors, such as
government policy on the matter, are usually involved in the decisions.
There are, of course, limits to the exercise of administrative discretion. Administrative
proceedings may be reviewed by the courts upon a showing that "the board or official has gone
beyond his statutory authority, exercised unconstitutional powers or clearly acted arbitrarily and
without regard to his duty or with grave abuse of discretion" or that the decision is vitiated by
fraud, imposition or mistake.