Case Summary (G.R. No. 148106)
Factual Background
Petitioner supplied intravenous fluid products to government hospitals of the Province under a series of invoices evidencing deliveries. As of February 28, 1998, petitioner claimed an outstanding balance of ₱487,662.80. Under the invoice terms, the Province promised to pay without need of demand on specified dates. Despite repeated demands and dialogues, the Province allegedly failed to remit full payment. Respondent admitted most factual allegations but asserted that some payments were unaccounted for and that it was diligently determining the correct amount owed.
Procedural History
Euro-Med filed a complaint for sum of money (Civil Case No. 5300) in the Regional Trial Court (RTC) of Batangas City. After petitioner’s evidence presentation, respondent moved to dismiss on grounds that the Commission on Audit (COA) held primary jurisdiction over money claims against local government units. On March 7, 2001, the RTC granted the motion and dismissed the complaint without prejudice to filing an appropriate claim with COA. A motion for reconsideration was denied on May 16, 2001, prompting this petition for certiorari under Rule 45.
Issue on Primary Jurisdiction
Whether the RTC or the Commission on Audit has primary jurisdiction to adjudicate petitioner’s money claim against the Province of Batangas.
Applicable Constitutional and Statutory Provisions
1987 Constitution (Article VIII, Section 1) vests judicial power in the Supreme Court and lower courts to settle actual controversies. The Government Auditing Code (PD 1445, Section 26) grants the COA authority to examine, audit, and settle all debts and claims due to or owing from the Government or its subdivisions. The Local Government Code (Republic Act No. 7160, Title VI, Book II) and COA Circular No. 92-386 implement rules on procurement, supply, and property management in local government units.
Doctrine of Primary Jurisdiction
Under the doctrine, courts must defer to specialized administrative bodies when the resolution of claims requires expertise or interpretation of regulatory schemes assigned to those bodies. Where enforcement of an otherwise judicially cognizable claim involves issues falling squarely within an agency’s statutory competence, the court may suspend or dismiss proceedings pending administrative determination.
Application to the Present Case
Petitioner sought enforcement of a fixed-amount claim against a local government unit. The amount was readily determinable from invoices and delivery receipts, satisfying COA’s remit over “liquidated claims.” Moreover, the claim arose from procurement of medical supplies governed by Local Government Code provisions and COA’s implementing rules on supply and property management. Determination of compliance with those procurement and
...continue readingCase Syllabus (G.R. No. 148106)
Facts of the Case
- From 19 August 1992 to 11 August 1998, Euro-Med Laboratories, Phil., Inc. supplied various Intravenous Fluids (IVF) products to government hospitals of the Province of Batangas.
- Deliveries were evidenced by invoices duly received and signed by the province’s authorized representatives.
- As of 28 February 1998, the unpaid balance allegedly amounted to ₱487,662.80.
- Under the invoices’ terms, the province covenanted to pay plaintiff without need of demand on specified dates.
- Petitioner made several demands and sought dialogues, all of which proved fruitless; respondent nevertheless failed to settle the outstanding accounts.
Procedural History
- Petitioner filed Civil Case No. 5300 in the Regional Trial Court (RTC) of Batangas City, Branch 84 (Executive Judge Paterno V. Tac-an), to recover ₱487,662.80.
- In its answer, respondent admitted most factual allegations but denied the exact amount owed, claiming unreflected payments and ongoing efforts to ascertain the true liability.
- After pre-trial and presentation of petitioner’s evidence, respondent moved to dismiss, asserting that the primary jurisdiction over the money claim lay with the Commission on Audit (COA) under the Local Government Code and COA rules.
- On March 7, 2001, the RTC granted the motion and dismissed the complaint without prejudice to filing with the COA.
- On May 16, 2001, the RTC denied petitioner’s motion for reconsideratio