G.R. No. 210950 - Enriquez vs. The Mercantile Insurance Co., Inc.

On 18 October 1988, the Philippine Coconut Authority (PCA) Governing Board passed Resolution No. 109-88 creating an Investigation Committee to look into a complaint by Antonio Pua against Leandro P. Garcia, then PCA Administrator, for alleged irregularities.
The Board amended the composition of the Committee on 7 February 1989 (Resolution No. 011-89) and again on 14 February 1989.
After formal hearings, the Committee submitted findings on 28 February 1989, stating there was a prima facie case against Garcia for dishonesty, falsification of official documents, grave misconduct, and violations of RA 3019 based on documentary evidence and witness testimonies.
The Committee recommended filing formal charges against Garcia and placing him under preventive suspension until the case was resolved.

On 1 March 1989, the PCA filed a formal administrative complaint (Special PCA Administrative Case No. 01-89) against Garcia for dishonesty, falsification, grave misconduct, and RA 3019 violations related to the grant of export quota for "fresh young coconuts."
The Board, by Resolution No. 021-89 dated 28 February 1989, placed Garcia under preventive suspension effective 6 March 1989.

Garcia, through his counsel, requested extensions to file his answer—first 15 days, then 30 days—which were granted with a caution that no further extension would be given.
The Investigation Committee scheduled hearings for May and June 1989; Garcia was duly notified.
On 3 May 1989, Garcia filed his answer but also requested postponements due to counsel’s unavailability. The Committee rescheduled hearings accordingly.
Garcia and his counsel repeatedly failed to appear during the hearings from 9 May onwards despite notices and denied participating in the proceedings after the Committee refused requests for a reconstituted investigation panel.

On 30 May 1989, the Board passed Resolution No. 046-89 holding that delays caused by petitioner will not count towards the period of preventive suspension and that reinstatement requires prior notice from the Board.
On 7 June 1989, Garcia filed a petition for certiorari, mandamus, and prohibition with prayer for preliminary injunction before the Regional Trial Court (RTC), seeking to enjoin respondents from proceeding with the administrative case and implementing Resolution No. 046-89.
The RTC issued a status quo order on 9 June 1989, and on 29 June 1989, issued a writ of preliminary injunction restraining the PCA Board from implementing the resolution.

Garcia sought the creation of a new Investigation Committee via motion dated 4 July 1989, which was denied by the RTC.
The RTC conducted evidentiary hearings on this incident and on 26 July 1989 issued a TRO enjoining the Committee from conducting further investigations for 20 days, pending hearing of respondents’ evidence.
Despite the TRO, on 21 August 1989, the Committee submitted its resolution finding Garcia guilty and recommending forced resignation, which the Board adopted on 25 August 1989 (Resolution No. 070-89).
Garcia filed a supplemental petition seeking to enjoin the Board from implementing Resolution No. 070-89; the RTC issued a TRO on 11 September 1989, which was converted to a preliminary injunction on 25 September 1989.
The Board’s motions for reconsideration were denied; the Board elevated the case to the Supreme Court.
The Supreme Court issued a temporary restraining order on 27 March 1990 and referred the case to the Court of Appeals (CA-G.R. SP No. 20384).

On 17 September 1990, the Court of Appeals set aside the RTC orders granting preliminary injunctions.
The RTC’s denial of petitioner’s motion for reconsideration was upheld by the CA on 16 May 1991.
Garcia then filed the present petition for review before the Supreme Court challenging the CA decision.

Whether the RTC gravely abused its discretion in issuing the preliminary injunctions against the PCA Board and Investigation Committee in the administrative disciplinary proceedings against Garcia.

Whether Garcia’s administrative due process rights were violated during the investigation and hearing process conducted by the PCA.

Whether Garcia’s failure to exhaust administrative remedies may be excused as an exception to the rule, allowing judicial intervention prior to the exhaustion of administrative procedures.