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As to the first issue, the immutability rule applies only w hen the decision is promulgated by a court possessed of

jurisdiction to hear and decide the case. Undoubtedly, the petition in the guise of a case for mandamus is a money
claim falling within the original and exclusive jurisdiction of this Commission. Noting the propensity of the lower
courts in taking cognizance of cases filed by claimants in violation of such primary jurisdiction, the Supreme Court
issued Administrative Circular 10-2000 dated October 23, 2000 enjoining judges of lower courts to exercise caution
in order to prevent "possible circumvention of the rules and procedures of the Commission on Audit" and
reiterating the basic rule that: "All money claims against the Government must be filed w ith the Commission on
Audit which shall act upon it within sixty days. Rejection of the claim w ill authorize the claimant to elevate the
matter to the Supreme Court on certiorari and in effect sue the State thereby."

Under the doctrine of primary jurisdiction, w hen an administrative body is clothed w ith original and exclusive
jurisdiction, courts are utterly w ithout pow er and authority to exercise concurrently such jurisdiction. Accordingly,
all the proceedings of the court in violation of that doctrine and all orders and decisions reached
thereby are null and void. It w ill be noted in the cited Supreme Court Circular that money claims are cognizable by
the COA and its decision is appealable only to the Supreme Court. The low er courts have nothing to do with such
genus of transactions

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