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AS DISTINGUISHED FROM application in concrete

ADMINISTRATIVE BODY contested cases in court, as the


Court explained in Santiago v.
 For example, an administrative
Bautista.
body, like the office of the
public prosecutor, tasked by REASONS FOR CREATION OF QUASI-
law to determine whether or JUDICIAL AGENCIES
not probable cause exists to
 There is a need for the ACTIVE
warrant the filing in court of
INTERVENTION of
criminal charges for violation of
ADMINISTRATIVE AGENECIES in
a penal statute and to handle
dealing with matters calling for
its prosecution is not a quasi-
technical knowledge and speed
judicial body.
in countless controversies
 Why? It is still an
which cannot possibly be
administrative body exercising
handled by regular courts.
a function which is principally
 Furthermore, as a result of the
administrative or executive in
growing complexity of the
nature.
modern society, it has become
 However, in Cojuangco v.
necessary to create more and
PCGG, the Court held that by
more administrative bodies to
the very nature of his function,
help in the regulation of its
a prosecutor is and must be
ramified activities.
considered to be a quasi-
 So again, that is the reason for
judicial officer, subject to the
the increasing vesture of quasi-
due process requirement of
legislative and quasi-judicial
the cold neutrality of an
power.
impartial judge. The ruling
accentuates the difficulty of VOLUNTARY ARBITRATOR A QUASI-
drawing the line between JUDICIAL OFFICER
administrative function and  I would just like to mention
quasi-judicial power, and that there are two types of
where to draw the line arbitration: VOL and INVOL.
between one and the other  Voluntary arbitration is the
may not be generalized but referral of a dispute by the
may only be done by actual parties pursuant to a voluntary
arbitration clause or the subject matter is the power
agreement to an impartial third to hear and determine the
person or panel for a final general class to which the
resolution. Involuntary proceedings in question
arbitration is one compelled by belong; it is conferred by law
the government to accept the and not by the consent or
resolution of the dispute acquiescence of any or all of
through the arbitration of a the parties or by erroneous
third party. belief of the court that it
 The voluntary arbitrator or exists.34 Thus, when a court has
panel of arbitrators makes the no jurisdiction over the subject
award or decision which matter, the only power it has is
becomes final after a certain to dismiss the action.
period from receipt of the copy
JURISDICTION, EXTENT
of the award or decision by the
parties. By the nature of his  The rule is that an
functions, a voluntary administrative body to which
arbitrator acts in quasi-judicial quasi-judicial power has been
capacity. delegated is a tribunal of
limited jurisdiction and as such
JURISDICTION it could wield only such powers
 In the case of MITSUBISHI as are specifically granted to it
MOTORS PHILIPPINES by its enabling statute. Its
CORPORATION, Petitioner, vs. jurisdiction is interpreted in
BUREAU OF CUSTOMS, strictissimi juris. This rule is
jurisdiction is defined as the based on the settled principle
power and authority of a court that an administrative agency
to hear, try, and decide a or officer can exercise only
case. In order for the court or such powers as are expressly
an adjudicative body to have granted as well as those which
authority to dispose of the case are necessarily implied
on the merits, it must acquire, therefrom.
among others, jurisdiction over
the subject matter. It is
axiomatic that jurisdiction over

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