G.R. No. 198426 - Republic vs. Principalia Management and Personnel Consultants, Inc.

The petitioner is the Republic of the Philippines, represented by the Philippine Overseas Employment Administration (POEA).
The respondent is Principalia Management and Personnel Consultants, Inc., a recruitment agency.

On June 8, 2009, the POEA issued an Order (POEA Case No. RV 07-03-0442) finding Principalia guilty of collecting excessive placement fees from a complainant, Alejandro Ramos, violating Section 2(b), Rule I, Part VI of the 2002 POEA Rules and Regulations.
The violation was deemed serious, warranting the penalty of license cancellation as first offense under Section 1A (6), Rule IV, Part VI of the POEA Rules.
Accordingly, upon receipt of the Order on June 24, 2009, the POEA immediately canceled Principalia’s license pursuant to Section 5, Rule V, Part VI of the POEA Rules, which mandates immediate executory effect where the imposed penalty is cancellation of license.

On June 26, 2009, Principalia filed a Complaint for Injunction with Application for Temporary Restraining Order (TRO) before the Regional Trial Court (RTC) of Mandaluyong City, seeking to stay the immediate license cancellation.
Principalia argued that the immediate cancellation deprived it of due process and jeopardized the deployment of hundreds of overseas Filipino workers.
The RTC, via its Executive Judge, issued a 72-hour TRO to allow six workers to deploy as scheduled.
Meanwhile, on July 8, 2009, Principalia also appealed the POEA Order with the Secretary of the Department of Labor and Employment (DOLE Secretary).

On July 22, 2009, POEA filed a Motion to Dismiss before the RTC on the grounds of lack of jurisdiction, non-exhaustion of administrative remedies, and forum-shopping.
POEA argued:

Jurisdiction over cancellation and appeals lies exclusively with the DOLE Secretary, not the RTC.
Principalia failed to exhaust administrative remedies by not appealing first to the DOLE Secretary.
Principalia committed forum-shopping by filing both the injunction with the RTC and the appeal with the DOLE Secretary.

It had jurisdiction under Section 21 of Batas Pambansa Blg. 129 (Judiciary Reorganization Act) as amended by RA 7691 over injunctions.
The exception to exhaustion applies due to probable irreparable damage from immediate license cancellation.
No forum-shopping occurred because the RTC action and DOLE appeal involved different parties and reliefs.

The Republic filed a Petition for Certiorari and Prohibition with the CA questioning the RTC’s jurisdiction in denying the Motion to Dismiss.
On April 4, 2011, the CA affirmed the RTC’s jurisdiction, holding that the injunction case merely sought to enjoin the immediate enforcement of the license cancellation, not to reverse the POEA Order.
The CA noted the RTC had not ruled on the merits yet, so there was no interference with DOLE Secretary’s administrative jurisdiction.
The CA denied the Republic’s Motion for Reconsideration on August 31, 2011.

On May 22, 2013, Principalia filed a Motion to Dismiss before the RTC, stating the issues had become moot and academic in light of its license renewal.
The RTC granted the motion and dismissed the injunction case on June 5, 2013.
Principalia argued the Petition was moot due to renewal and no longer served any practical purpose.
The Republic contended that the Petition was not moot and that resolving the jurisdictional question was important to settle pending similar cases nationwide.
The Republic maintained that Principalia did not exhaust administrative remedies and committed forum-shopping.

Whether the Regional Trial Court has jurisdiction to hear and decide the injunction case filed by Principalia seeking to stop the immediate enforcement of the POEA Order canceling its recruitment license.
Whether the Petition filed by the Republic is moot and academic.
Whether the issuance of an injunction against immediate implementation of penalties imposed by the POEA is allowed despite exclusive administrative jurisdiction of the DOLE Secretary over appeals.
Whether Principalia committed forum-shopping by filing an injunction with the RTC while simultaneously appealing the POEA Order with the DOLE Secretary.
Whether the principle of exhaustion of administrative remedies applies to the case at bar and if any exceptions exist.