Case Summary (G.R. No. 198426)
Key Dates and Applicable Law
- POEA Order finding violation and directing immediate cancellation: June 8, 2009
- Corresponding RTC Orders denying dismissal of the injunction case: July 28, 2009 and October 5, 2009
- Court of Appeals (CA) Decision affirming RTC jurisdiction: April 4, 2011
- CA Resolution denying motion for reconsideration: August 31, 2011
- Petition for review filed by the Republic before the Supreme Court: October 20, 2011
- Relevant legal instruments include the 1987 Constitution, the 2002 POEA Rules and Regulations (particularly Part VI dealing with sanctions), Batas Pambansa Blg. 129 (Judiciary Reorganization Act of 1980) as amended by Republic Act No. 7691, and Executive Order No. 247.
Factual Background and Initial Administrative Proceedings
The POEA found Principalia guilty of a serious violation under Section 2(b), Rule I, Part VI of the 2002 POEA Rules for charging excessive fees, which carries the maximum administrative penalty of license cancellation for a first offense. Pursuant to Section 5, Rule V, Part VI of the POEA Rules, the penalty of cancellation was immediately executory despite the pendency of any appeal. Principalia filed for an injunction with the RTC seeking to restrain the immediate cancellation on due process grounds, citing possible irreparable injury and jeopardy to the deployment of overseas Filipino workers.
RTC’s Jurisdiction and Orders
The RTC denied POEA’s Motion to Dismiss, ruling that:
- The court has jurisdiction over injunction actions under Section 21 of BP 129 as amended by RA 7691.
- The exhaustion of administrative remedies rule does not apply because Principalia would suffer irreparable harm from immediate license cancellation.
- No forum-shopping occurred, as the injunction case and the administrative appeal before the DOLE Secretary involved different reliefs.
The RTC upheld these rulings despite POEA’s motion for reconsideration.
Court of Appeals Decision
The CA affirmed the RTC’s exercise of jurisdiction over the injunction case, distinguishing the relief sought—an injunction against immediate enforcement of the cancellation order—from an appeal of its merits, which falls within the exclusive jurisdiction of the DOLE Secretary. The CA held that the 2002 POEA Rules do not divest the courts of jurisdiction to entertain injunction petitions against administrative orders imposing penalties, especially when grave abuse of discretion is alleged. The CA further held that the RTC’s issuance of the TRO did not infringe upon the DOLE Secretary’s authority since the merits of the underlying POEA order were not yet adjudicated.
Subsequent Developments and Mootness of the Case
Principalia filed a motion to dismiss the injunction case, citing the lapse of time and renewal of its recruitment license by POEA, rendering the issues moot and academic. The RTC granted dismissal accordingly. Principalia argued that the petition before the Supreme Court is moot given the license renewal and no longer presents an actual controversy. The Republic contended the case should be decided for the guidance of lower courts and the administrative agency, noting the recurring nature of similar cases.
Issue Presented
Whether the RTC had jurisdiction to entertain the injunction case seeking to restrain the immediate execution of the POEA order cancelling Principalia’s license.
Supreme Court’s Ruling – Mootness and Jurisdiction
The Supreme Court found the case moot and academic because Principalia’s license was renewed, removing the immediate enforcement issue that sparked the injunction suit. A case is moot and academic when, due to supervening events, no actual controversy remains and no useful purpose would be served in adjudicating the matter.
Nonetheless, invoking the “capable of repetition yet evading review” exception, the Court proceeded to rule on the jurisdictional issue for the benefit of the bar, bench, and administrative agencies.
The Court held that:
- Under EO 247 and the 2002 POEA Rules, the POEA has original and exclusive jurisdiction over administrative violations regarding recruitment agencies and license conditions, with appeals falling exclusively under the DOLE Secretary.
- However, these rules do not explicitly preclude courts from entertaining injunctions against immediate enforcement of administrative penalties such as cancellation or suspension of license for serious offenses.
- The RTC rightfully exercised jurisdiction over the injunction petition pursuant to Section 19 of BP 129 as amended by RA 7691, which grants RTC exclusive original jurisdiction over civil actions where the subject cannot be pecuniarily estimated, including injunctions.
- Injunction is a proper remedy to prevent grave abuse of discretion or excess of jurisdiction by an administrative agency, especially when fundamental rights or due process are allegedly violated.
- The filing of separate actions before the RTC and the DOLE Secretary do not constitute forum shopping when the reliefs sought differ in nature—injunctive relief versus appeal
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Case Syllabus (G.R. No. 198426)
Facts of the Case
- The Philippine Overseas Employment Administration (POEA) found Principalia Management and Personnel Consultants, Inc. (Principalia), a recruitment agency, guilty of charging an excessive placement fee from complainant Alejandro Ramos, violating Section 2(b), Rule I, Part VI of the 2002 POEA Rules and Regulations.
- This violation is classified as a serious offense carrying the penalty of cancellation of license for the first offense.
- On June 8, 2009, the POEA issued an order for cancellation of Principalia’s license effective immediately upon receipt of the order on June 24, 2009, pursuant to Section 5, Rule V, Part VI of the POEA Rules which requires immediate executory effect when the penalty involves cancellation or suspension for more than 12 months.
- Principalia filed a Complaint for Injunction with Application for Temporary Restraining Order (TRO) with the Regional Trial Court (RTC) of Mandaluyong City on June 26, 2009, challenging the immediate cancellation as a deprivation of due process and a threat to overseas Filipino workers' deployment.
- The RTC issued a 72-hour TRO to allow scheduled deployment.
- Principalia simultaneously appealed the POEA order with the Department of Labor and Employment (DOLE) Secretary on July 8, 2009.
- POEA filed a Motion to Dismiss before the RTC, arguing lack of jurisdiction, failure to exhaust administrative remedies, and forum-shopping, asserting that only the DOLE Secretary has jurisdiction over such appeals and injunctions are improper.
Ruling of the Regional Trial Court (RTC)
- On July 28, 2009, the RTC denied POEA’s Motion to Dismiss, holding that:
- Jurisdiction over injunctions lies with the RTC under Section 21 of Batas Pambansa Blg. 129 (Judiciary Reorganization Act of 1980) as amended by RA 7691.
- The principle of exhaustion of administrative remedies has exceptions, including potential irreparable damage here caused by immediate license cancellation.
- No forum-shopping existed due to differing parties and reliefs in the injunction suit and departmental appeal.
- The RTC denied reconsideration filed by POEA on October 5, 2009.
Ruling of the Court of Appeals (CA)
- On April 4, 2011, the CA affirmed the RTC rulings, holding:
- The injunction case aims to question the legality or propriety of the immediate execution of the cancellation order, not the merits of the cancellation itself, which falls under the DOLE Secretary's exclusive jurisdiction.
- The 2002 POEA Rules cannot deprive regular courts of jurisdiction to entertain injunction complaints.
- There was no grave abuse of discretion from the RTC in assuming jurisdiction and issuing the orders.
- The CA denied the Republic’s Motion for Reconsideration on August 31, 2011.
- The CA emphasized that the RTC had not yet ruled on the injunction's merits and thus did not encroach upon the DOLE Secretary's exclusive authority over appeals.
Subsequent Proceedings and Dismissal
- Principalia filed a Motion to Dismiss on May 22, 2013, citing mootness due