Case Digest (G.R. No. 264268)
Facts:
Mary Ann Cabailo filed a complaint with the DTI Regional Office VI alleging that Chris Art L. Normandy, owner of Valkyrie Construction, undertook construction of her second floor for PHP 1.2 million beginning May 3, 2016, stopped works in November 2017 leaving alleged defects and incompleteness, and was not a duly licensed contractor under the PCAB. The DTI Adjudication Officer, in a Decision dated August 3, 2018, found Normandy guilty of violating Section 35 of Republic Act No. 4566 for engaging in contracting without a PCAB license and ordered cease and desist, cancellation of business registration, and fines; the Court of Appeals initially reversed but in its Amended Decision dated August 24, 2022 reinstated the DTI rulings, prompting this Rule 45 petition to the Supreme Court.
Issues:
- Did the Court of Appeals err in affirming that the DTI had jurisdiction over the complaint against Chris Art L. Normandy?
Ruling:
The petition was granted. The Supreme Court reversed the Amended Decision of the Court of Appeals dated August 24, 2022, and dismissed the complaint against Chris Art L. Normandy for lack of subject-matter jurisdiction in the DTI.
Ratio:
The Court held that the Contractors' License Law (Republic Act No. 4566) and its IRR vest investigatory and disciplinary jurisdiction in the PCAB over acts defined in the statute, including persons who undertake contracting without first securing a license, because the statute uses the term “any person.” An administrative issuance cannot enlarge an agency's powers beyond its statutory grant; thus DTI DAO No. 07-06, to the extent it asserted DTI jurisdiction over violations defined by RA 4566, conflicted with the statute and could not supplant the PCAB's statutory jurisdiction, rendering the DTI proceedings null and void.
Doctrine:
- Republic Act No. 4566 vests jurisdiction to investigate and discipline contractors in the PCAB, including persons acting as contractors without a license.
- The statutory phrase “any person” includes unlicensed individuals or entities who undertake contracting.
- An administrative rule cannot expand an agency's jurisdiction beyond what the enabling statute authorizes.
- When a statute and an administrative order conflict, the statute prevails.
- Lack of subject-matter jurisdiction renders administrative actions null and void.