G.R. No. 175039 - Addition Hills Mandaluyong Civic and Social Organization, Inc. vs. Megaworld Properties and Holdings, Inc.

Samar II Electric Cooperative, Inc. (SAMELCO II) is an electric cooperative organized under Presidential Decree (P.D.) No. 269, as amended by P.D. No. 1645.
The individual petitioners are members of SAMELCO II’s Board of Directors, while respondent Ananias D. Seludo, Jr. had been elected as a board member in 2002 and his term expired in May 2005.

On January 22, 2005, certain board members, acting collectively as part of the BOD, adopted Resolution No. 5 [Series] of 2005.
The resolution was twofold in nature:

It barred respondent from attending subsequent Board of Directors meetings effective February 2005 until the end of his term.
It disqualified respondent from running as a candidate for director in the upcoming district elections.

As a consequence of the resolution, respondent contended that his rights as a director were being curtailed arbitrarily.
He filed an Urgent Petition for Prohibition in the Regional Trial Court (RTC) of Calbiga, Samar, seeking:

The nullification of Resolution No. 5 on the ground of lack of legal and factual basis.
The issuance of a temporary restraining order (TRO) or a writ of preliminary injunction to prevent the enforcement of the board resolution.

The RTC initially granted a TRO effective for 72 hours, which was later extended for another 17 days.

In its answer, the Board members raised an affirmative defense regarding lack of subject-matter jurisdiction by insisting that the National Electrification Administration (NEA) has primary jurisdiction over matters involving electric cooperatives.
The RTC, in its May 6, 2005 Order, sustained jurisdiction over the petition while barring the petitioners from enforcing the resolution.
Upon filing a motion for reconsideration, the RTC, and subsequently the Court of Appeals (CA) in its January 26, 2006 Decision and July 12, 2006 Resolution, denied the relief sought by the board members and affirmed the RTC’s orders.

Whether the doctrine of primary jurisdiction should be narrowly interpreted—limited solely to cases involving highly technical or specialized disputes—or whether it extends to matters arising from disputed board resolutions in electric cooperatives.
Whether the NEA’s supervisory and control powers, as enhanced by P.D. No. 1645, give it primary jurisdiction over the validity of board resolutions affecting the management of electric cooperatives.

Whether the RTC had proper jurisdiction over the petitioner’s Urgent Petition for Prohibition in light of the NEA’s express powers as provided by P.D. Nos. 269 and 1645.
Whether issues raised by the petition, particularly those regarding due process and the validity of the resolution, fall within the technical expertise and primary jurisdiction of the NEA.

Whether respondent’s failure to exhaust the administrative remedy available via the NEA should preclude him from seeking judicial intervention through a petition for prohibition.
Whether the existence of an alternative, plain, speedy, and adequate administrative remedy negates the issuance of a writ of prohibition.