Facts:

The case involves Bloomfield Academy and Rodolfo J. Lagera as petitioners against the Court of Appeals, the Bloomfield Academy Parents Advisory Association, Inc. (BAPAA), represented by its Vice-President Menardo Bordeos, and Hon. Salvador P. De Guzman, Jr., the Presiding Judge of the Regional Trial Court, National Capital Judicial Region, Branch 142, Makati, Metro Manila, as respondents. The events leading to this case began on April 6, 1990, when BAPAA filed a complaint for injunction against Bloomfield Academy, a non-stock, non-profit educational institution, regarding an increase in tuition fees. The complaint alleged that the school had decided to raise tuition fees by an average of 21.22% without prior consultation with the parents, which was a requirement under Republic Act No. 6728. The increase was justified by the school on the grounds of compliance with the mandatory minimum wage increase under R.A. 6727. The parents contended that the tuition fees were already amo...

Facts:

1. Parties Involved:

   • Petitioners: Bloomfield Academy and Rodolfo J. Lagera.
   • Respondents: The Honorable Court of Appeals, Bloomfield Academy Parents Advisory Association, Inc. (BAPAA), represented by its Vice-President Menardo Bordeos, and the Hon. Salvador P. De Guzman, Jr., Presiding Judge of the Regional Trial Court, Branch 142, Makati, Metro Manila.

2. Dispute:

   • The case originated from a complaint filed by BAPAA against Bloomfield Academy and its president, Rodolfo J. Lagera, challenging the increase in tuition fees for the school year 1989-1990.

3. Tuition Fee Increase:

   • Bloomfield Academy increased tuition fees by an average of 21.22%, citing the mandatory wage increase under Republic Act (R.A.) No. 6727 as justification.
   • The increase was implemented without prior consultation with the parents, as required by law.

4. Legal Basis for Increase:

   • The petitioners argued that the increase was necessary due to the wage hike mandated by R.A. No. 6727.
   • The Department of Education, Culture, and Sports (DECS) approved a 50% increase, but the petitioners implemented the full increase, contrary to an alleged agreement with the parents to limit the increase to 50%.

5. Court Proceedings:

   • BAPAA filed a complaint for injunction with a prayer for a temporary restraining order (TRO) to stop the implementation of the tuition fee increase.
   • The Regional Trial Court (RTC) issued a writ of preliminary injunction, limiting the tuition fee increase to 50% and preventing the withholding of report cards or transfer documents.

6. Appeal to the Court of Appeals:

   • The petitioners filed a special civil action for certiorari with the Court of Appeals, challenging the RTC's issuance of the writ of preliminary injunction.
   • The Court of Appeals dismissed the petition, ruling that the RTC did not commit grave abuse of discretion.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction Over Administrative Decisions:

   • The Court reiterated that decisions of administrative agencies, such as the DECS, must first be appealed to the appropriate appellate court (in this case, the Court of Appeals) before resorting to judicial action.

2. Doctrine of Primary Jurisdiction:

   • The Court emphasized the doctrine of primary jurisdiction, which requires that disputes involving specialized knowledge or expertise (e.g., tuition fee increases) be first resolved by the relevant administrative agency.

3. Exhaustion of Administrative Remedies:

   • The Court held that the failure to exhaust administrative remedies before filing a judicial action is a fatal flaw, as it deprives the court of jurisdiction over the case.

4. Arbitration as a Preferred Remedy:

   • The Court highlighted that arbitration is the preferred remedy for resolving disputes over tuition fee increases, as provided under R.A. No. 6728.

5. Errors of Judgment vs. Errors of Jurisdiction:

   • The Court clarified that errors of judgment (e.g., factual or legal errors in the RTC's decision) are not correctible through a special civil action for certiorari, which is only available to correct errors of jurisdiction or grave abuse of discretion.