Title
Garcia vs. Court of Appeals
Case
G.R. No. 100579
Decision Date
Jun 6, 2001
PCA Administrator Garcia challenged preventive suspension and administrative proceedings, alleging due process violations; SC upheld exhaustion of remedies, affirming PCA's actions.

Case Summary (G.R. No. 210950)

Factual background of the administrative complaint and preliminary committee actions

An external complainant, Antonio Pua, alleged irregularities against petitioner in connection with grants of export quota. The PCA Governing Board created an Investigation Committee by Board Resolution No. 109-88, later altering its composition by subsequent resolutions (Nos. 011-89, 017-89, 039-89) in response to petitioner’s claims of partiality. The Investigation Committee conducted hearings, received documentary evidence, and on 28 February 1989 reported that a prima facie case existed against Garcia on specified issues and recommended formal charges and preventive suspension pending resolution.

Filing of the administrative case, preventive suspension, and scheduling

On 1 March 1989 an administrative complaint was filed (Special PCA Administrative Case No. 01-89) for dishonesty, falsification of official documents, grave misconduct and violation of R.A. No. 3019. The Board placed petitioner under preventive suspension effective upon receipt of notice (6 March 1989). Petitioner requested and obtained extensions to file his answer, and multiple hearing dates were set for May and June 1989. Petitioner’s counsel intermittently requested postponements; at times petitioner and/or counsel failed to appear despite notices.

Board determination on computation of preventive suspension period

By Board Resolution No. 046-89 (30 May 1989) the PCA declared that periods of delay attributable to petitioner’s motions, requests for extension, and postponements would not be counted in calculating the 90-day period for preventive suspension under Section 42, P.D. 807, and advised that re-assumption of office would require prior notice by the Governing Board.

Petition to the RTC and early judicial intervention

On 7 June 1989 petitioner filed a petition for certiorari, mandamus and prohibition with prayer for a preliminary injunction in the RTC seeking to enjoin the Investigation Committee from proceeding, to restrain the Board from implementing Resolution No. 046-89, and to defer Board action pending judicial resolution. The RTC issued a status quo order (9 June 1989) and later a writ of preliminary injunction (29 June 1989) enjoining implementation of Resolution No. 046-89. The RTC also entertained petitioner’s later motions for a new investigating committee and restraining orders. The RTC issued a TRO on 26 July 1989 restraining the Committee from conducting investigation for twenty days and later, on 11 and 25 September 1989, issued orders enjoining implementation of the committee’s and Board’s resolutions that imposed forced resignation.

Committee resolution, Board action, and conflicting timelines

Despite the RTC TRO of 26 July 1989, the Investigation Committee finalized its resolution on 21 August 1989 finding Garcia guilty and recommending forced resignation; the Board adopted the recommendation by Resolution No. 070-89 on 25 August 1989, effecting the penalty on 31 August 1989. Petitioner sought to enjoin implementation; the RTC issued a temporary restraining order and later a writ of preliminary injunction against enforcement, which prompted the respondents to elevate the matter to the Supreme Court and for referral to the Court of Appeals.

Court of Appeals decision and grounds for reversal of RTC orders

The Court of Appeals, in CA-G.R. SP No. 20384, set aside the RTC orders of 29 June and 25 September 1989 that had granted preliminary injunctive relief to petitioner, reasoning principally that: (a) the RTC had gravely abused its discretion by issuing the preliminary injunction; (b) the TRO issued on 26 July 1989 had a limited statutory life (20 days under BP Blg. 224) and had become functus officio by 15 August 1989, so the Committee and Board were not legally restrained when they acted on 21 and 25 August 1989; and (c) the merits of the Board resolutions were within the exclusive original jurisdiction of the administrative agency with recourse available to petitioner by appeal to the Civil Service Commission, thus implicating the doctrine of primacy of administrative jurisdiction and exhaustion of administrative remedies.

Issues raised in the Supreme Court petition for review

Petitioner urged three principal errors by the Court of Appeals: (1) that the RTC did not commit grave abuse of discretion in issuing its orders; (2) that the PCA violated petitioner’s administrative due process; and (3) that PCA’s alleged patent illegal acts should have been recognized as exceptions to the exhaustion of administrative remedies rule.

Legal analysis — primacy of administrative jurisdiction and exhaustion of remedies

The Supreme Court affirmed the primacy of administrative jurisdiction in disciplinary cases against public officers under P.D. 807 and related rules. The Court reiterated the doctrine that, where an adequate administrative remedy exists (here, administrative adjudication before the PCA with appeal to the Civil Service Commission), judicial intervention is improper until those remedies are exhausted. The Court agreed with the appellate court that petitioner’s immediate resort to the courts while the administrative investigation was ongoing was premature; the availability of an administrative appeal rendered the judicial petition untimely and improper.

Legal analysis — preventive suspension, Section 42 of P.D. 807, and the effect of petitioner’s requests

Section 42 of P.D. 807 provides automatic reinstatement if an administrative case is not finally decided within 90 days unless delays are attributable to the respondent. The PCA’s Resolution No. 046-89, excluding periods of delay caused by petitioner’s extensions and postponements in computing preventive suspension, was consistent with Section 42. The record indicated petitioner’s multiple requests for extensions and his refusal to attend scheduled hearings despite due notice, which supported the PCA’s decision to exclude those periods from the 90‑day computation.

Legal analysis — due process and opportunity to be heard

The Court found that petitioner was afforded adequate administrative due process. Due process in disciplinary proceedings requires a meaningful opportunity to be heard and to present a defense; petitioner filed an answer and was repeatedly given postponements and accommodations, but he failed to appear at scheduled hearings. The Court relied on precedent (e.g., Tajonera v. Lamaroza) on the principle that the absen

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