RULE MAKING POWER OF THE SC PRINCIPLE OF JUDICIAL HEIRARCHY DOCTRINE OF

NON-INTERFERENCE/JUDICIAL
STABILITY
EXTENT OF THE RULE-MAKING POWER OF THE SC. (2017 BAR) The principle provides that lower courts shall initially decide a case GR: Courts of EQUAL AND
before it is considered by a higher court.
It has the power to promulgate rules concerning: (Pro-PAILa) COORDINATE jurisdiction CANNOT
INTERFERE with each other’s orders.
1. The PROTECTION AND ENFORCEMENT of constitutional rights; A higher court will not entertain direct resort to it unless the redress (Riano, 2016, citing Lapu-Lapu
desired cannot be obtained in the appropriate courts. (Santiago v. Vasquez, G.R. Development and Housing
2. PLEADING, PRACTICE, AND PROCEDURE in all courts; NOTE: The Nos. 99289-90, January 27, 1993) Corporation v. Group Management
constitutional faculty of the Court to promulgate rules of practice Corporation, G.R. Nos. 167000 and
and procedure necessarily CARRIES THE POWER TO OVERTURN Pursuant to this principle, a case must be filed first before the lowest court 169971, June 8, 2011)
judicial precedents on points of remedial law through the possible having the appropriate jurisdiction, EXCEPT if one can advance a special
amendment of the Rules of Court. (Pinga v. The Heirs Of German reason which would allow a party a direct resort to a higher court. (Riano, 2019) The principle ALSO bars a court from
Santiago, G.R. No. 170354, June 30, 2006) REVIEWING OR INTERFERING with the
CONSTITUTIONAL IMPERATIVE: This doctrine is not mere policy, judgment of a co-equal court over
3. The admission to the practice of law; which it has no appellate jurisdiction.
rather, it is a CONSTITUTIONAL FILTERING MECHANISM designed to enable
(Riano, 2016)
the Court to focus on the more fundamental and essential tasks assigned
4. The INTEGRATED BAR; and
to it by the highest law of the land. (Gios-Samar, Inc. v. Department of No court can interfere by INJUNCTION
Transportation and Communications and Civil Aviation Authority of the with the judgments or orders of
5. Legal assistance to the underprivileged. (Art. VIII, Sec. 5[5], Philippines, G.R. No. 217158, March 12, 2019)
another court of concurrent
1987 Constitution)
jurisdiction having the power to grant
NOTE: The POWER TO REPEAL, ALTER, OR SUPPLEMENT rules
STRICT OBSERVANCE OF THE DOCTRINE OF HIERARCHY OF the relief sought by the injunction.
(Atty. Cabili v. Judge Balindog, A.M.
concerning pleading, practice and procedure in all courts belongs COURTS SHOULD NOT BE A MATTER OF MERE POLICY. IT IS A
No. RTJ-10-2225, September 6, 2011)
exclusively to the Supreme Court. CONSTITUTIONAL IMPERATIVE GIVEN:
Even in case of CONCURRENT
Q: Congress enacted a law that contains a provision prohibiting 1. The STRUCTURE OF OUR JUDICIAL SYSTEM.
plea-bargaining in drug-related cases. Is the provision valid? jurisdiction, court first
the
The doctrine of hierarchy of courts recognizes the various levels of courts in the acquiring jurisdiction
A: NO. Plea bargaining is a rule of procedure. As such, the country as they are established under the Constitution and by law, their ranking excludes the other courts.
provision prohibiting it that is contained in a statute is and effect of their rulings in relation with one another, and how these different (Pacific Ace Finance Ltd. [PAFIN] v. Eiji
unconstitutional for being contrary to the rule-making authority of levels of court interact with one another. It determines the venues of appeals Yanagisawa, G.R. No. 175303, April 11,
the Supreme Court. Only the Supreme Court can promulgate rules and the appropriate forum for the Issuance of extraordinary writs. Accordingly, 2012)
on pleadings, practice and procedure, not Congress through when litigants seek relief directly from the Court, they bypass the judicial
passage of a law. (Estipona v. Lobrigo, G.R. No. 226679, August 15, structure and open themselves to the risk of presenting incomplete or disputed
2017) facts. This consequently hampers the resolution of controversies before the
Court. Without the necessary facts, the Court cannot authoritatively determine
the rights and obligations of the parties. The case would then become another
 addition to the Court's already congested dockets; and
LIMITATIONS ON THE RULE-MAKING POWER OF THE XPN: The doctrine does not apply
SUPREME COURT (SIU-DIM) where a third-party claimant is
2. The REQUIREMENTS OF DUE PROCESS. By directly filing a case before the involved - this is in consonance with
1. The rules shall provide a SIMPLIFIED AND INEXPENSIVE Court, litigants necessarily deprive themselves of the oportunity to completely the well-established principle that NO
procedure for the speedy disposition of cases; pursue or defend their causes of actions. Their right to due process is effectively MAN SHALL BE AFFECTED BY ANY
undermined by their own doing. (Ibid.) PROCEEDING TO WHICH HE IS A
2. The rules must be UNIFORM for all the courts of the same STRANGER. (Sps. Crisologo v. Omelio,
grade; and NOTE: The doctrine of hierarchy of courts ENSURE that every level of the A.M. No. RTJ-12-2321, October 3,
judiciary PERFORMS its designated roles in an EFFECTIVE AND EFFICIENT 2012, citing Sec. 16, Rule 39, and
3. The rules must not DIMINISH, INCREASE OR MODIFY MANNER. (Maza v. Turla, G.R. No. 187094, February 15, 2017, as penned by J. quoting Naguit v. CA, G.R. No. 137675,
substantive rights. (Sec.5 [5], Art. VIII, 1987 Constitution) Leonen, citing The Diocese of Bacolod v. COMELEC, G.R. No. 206728, Januuary December 5, 2000)
21, 2015)
POWER OF THE SUPREME COURT TO AMEND AND SUSPEND RATIONALE
PROCEDURAL RULES TRIAL COURTS do not only DETERMINE the facts from the evaluation of the
evidence presented before them. They are likewise COMPETENT TO DETERMINE The rule is founded on the concept of
GR: Compliance with procedural rules is the general rule, and issues of law which may include the validity of an ordinance, statute, or even an jurisdiction:
abandonment thereof should only be done in the MOST executive issuance in relation to the Constitution. To effectively perform these
EXCEPTIONAL CIRCUMSTANCES. (Pilapil v. Heirs of Briones, G.R. functions, they are territorially organized into regions and then into branches. A court that acquires jurisdiction over
No. 150175, March 10, 2006) Their writs generally reach within those territorial boundaries. the case and renders judgment
NOTE: The courts have the power to relax or suspend technical or therein has jurisdiction over its
procedural rules or to except a case from their operation when Necessarily, they mostly perform the all-important task of inferring the facts judgment, to the exclusion of all other
compelling reasons so warrant or when the purpose of justice from the evidence as these are physically presented before them. In many coordinate courts, for its execution
requires it. (Commissioner of Internal Revenue v. Migrant Pagbilao instances, the facts occur within their territorial jurisdiction, which properly and overall its incidents, and to
Corporation, G.R. No. 159593, October 12, 2006) present the 'actual case' that makes ripe a determination of the constitutionality control, in furtherance of justice, the
of such action. The consequences, of course, would be national in scope. (Ha conduct of ministerial officers acting in
XPN: The power of the Supreme Court TO SUSPEND ITS OWN Datu Tawahig, et al v. Hon. Cebu City Prosecutor I Lineth Lapinid, et al., G.R. No. connection with this judgment.
RULES OR TO EXCEPT a particular case from its operations 221139, March 20, 2019, as penned by J. Leonen, citing The Diocese of Bacolod (United Alloy vs UCPB, G.R. No.
whenever the purposes of justice require it CANNOT BE v. COMELEC) 179257, November 23, 2015)
QUESTIONED. The rules of procedure should be viewed as
mere tools designed to facilitate the attainment of justice. Their
FILTERING MECHANISM. The doctrine of hierarchy of courts operates to: NOTE: The doctrine of non-
interference LIKEWISE APPLIES with
strict and rigid application, which would result in technicalities that
1. Prevent INORDINATE DEMANDS upon the Court's time and attention which equal force to administrative bodies.
tend to frustrate rather than promote substantial justice, must
are better devoted to those matters within its exclusive jurisdiction; (Philippine Sinter Corporation v.
always be avoided. (De Guzman v. Sandiganbayan, G.R. No.
Cagayan Electric Power and Light Co.,
103276, April 11, 1996)
2. Prevent further OVERCROWDING of the Court's docket; and Inc., G.R. No. 127371, April 25, 2002)
The power to suspend or even disregard rules can be so pervasive
3. Prevent the INEVITABLE AND RESULTANT DELAY, intended or otherwise, in
and compelling as to alter even that which the Supreme Court
the adjudication of cases which often have to be remanded or referred to the
itself had already declared to be final. (Apo Fruits Corporation v.
Land Bank of the Philippines, G.R. No. 154195, October 12, 2010)
Where STRONG CONSIDERATIONS OF SUBSTANTIVE JUSTICE are
manifest on the petition, the strict application of the rules of
procedure may be relaxed, in the exercise of its equity jurisdiction.
A rigid application of the rules of procedure will not be entertained
if it will obstruct rather than serve the broader interests of justice
in the light of the prevailing circumstances in the case under
consideration. (CTMC Int’l v. Bhagis Int’l Corp., G.R. No. 170488,
December 10, 2012)
XPN to XPN: To relieve a litigant of an injustice commensurate
with his failure to comply with the prescribed procedure and the
mere invocation of substantial justice is not a magical incantation
that will automatically compel the Court to suspend procedural
rules. (Co-Unjieng v. C.A., G.R. No. 139596, January 24, 2006)
Parties praying for the liberal interpretation of the rules must be
able to hurdle that HEAVY BURDEN OF PROVING that they
deserve an exceptional treatment. It was never the Court’s intent
“to forge a bastion for erring litigants to violate the rules with
impunity.” (Prieto v. Alpadi Development Corp., G.R. No. 191025,
July 31, 2013)
Reasons that would warrant the suspension of the
Rules of Procedure (EMeCLOT)
1. The EXISTENCE of special or compelling circumstances;
2. The MERITS of the case;
3. A CAUSE NOT ENTIRELY ATTRIBUTABLE to the FAULT OR
NEGLIGENCE of the party favored by the suspension of rules;
4. A LACK of any showing that the review sought is merely
frivolous and dilatory; 8. The petition includes questions that are dictated by PUBLIC WELARE and the
advancement of PUBLIC POLICY, or demanded by the BROADER INTEREST OF
5. The OTHER party will not be UNJUSTLY PREJUDICED thereby JUSTICE;
(Sarmiento v. Zaratan, G.R. No. 167471, February 5, 2007); and
9. The ORDERS complained of were found to be PATENT NULLITIES;
6. TRANSCENDENTAL matters of life, liberty or state security.
lower court as the proper forum under the rules of procedure, or as the court
better equipped to resolve factual questions.
EXCEPTIONS TO THE DOCTRINE OF HIERARCHY OF
COURTS (2017 BAR) In several cases, the court has allowed direct invocation
of the SC’s original jurisdiction on the following grounds:
1. When there are GENUINE ISSUES OF CONSTITUTIONALITY that must be
addressed at the most immediate time (The Diocese of Bacolod v. COMELEC,
supra.)
NOTE: A direct resort to the Supreme Court includes availing of the remedies of
certiorari and prohibition to assail the constitutionality of actions of both
legislative and executive branches of the government;
2. When the issues involved are of TRANSCENDENTAL IMPORTANCE
NOTE: In these cases, the imminence and clarity of the threat to fundamental
constitutional rights outweigh the necessity for prudence. The doctrine relating
to constitutional issues of transcendental importance prevents courts from the
paralysis of procedural niceties when clearly faced with the need for substantial
protection;
3. Cases of FIRST IMPRESSION (Ha Datu Tawahig, et al v. Hon. Cebu City
Prosecutor I Lineth Lapinid, et al., supra.);
4. The constitutional issues raised are better decided by the Supreme Court;
5. EXIGENCY in certain situations or when time is of the essence;
6. The filed petition reviews the act of a constitutional organ;
7. NO OTHER plain, speedy, and adequate remedy in the ordinary course of law;
(Mindanao Savings and Loan Association v. Vda. de Flores, G.R. No. 10. The APPEAL was considered as clearly an inappropriate remedy;
142022, September 7, 2005)
11. When ANALOGOUS, EXCEPTIONAL AND COMPELLING CIRCUMSTANCES
POWER TO STAY PROCEEDINGS AND CONTROL ITS called for and justified the immediate and direct handling of the case. (Republic
v. Caguioa, et al., G.R. No. 174385, February 20, 2013)
PROCESSES.

The power to stay proceedings is INCIDENTAL to the power COMMON DENOMINATOR

inherent in every court TO CONTROL THE DISPOSITION OF THE
CASES on its dockets, considering its time and effort, and that of A careful examination of the jurisprudential bases of the exceptions would reveal
counsel and the litigants. a common denominator – the issues for resolution of the Court are PURELY

But if proceedings must be stayed, it must be done in order to:

LEGAL. (Gios-Samar, Inc. v. Department of Transportation and
Communications and Civil Aviation Authority of the Philippines, supra.)
CAP -C
NOTE: The SC may disregard the principle of hierarchy of courts if warranted by
1. avoid multiplicity of suits and
the NATURE AND IMPORTANCE OF THE ISSUES RAISED in the interest of speedy
2.prevent vexatious litigations,
justice and to avoid future litigations. (Riano, 2011)
3. conflicting judgments, and
4. confusion between litigants and courts. (Security Bank Corp. v.
Judge Victorio, 468 SCRA 609 FAILURE TO COMPLY with the doctrine: Failure to comply with the
Principle of Hierarchy of Courts is SUFFICIENT CAUSE FOR THE DISMISSAL of the
petition. (Gios-Samar, Inc. v. Department of Transportation and Communications
and Civil Aviation Authority of the Philippines, supra.)