Case Summary (G.R. No. 173840)
Legal Framework
The cooperative was established under Presidential Decree (P.D.) No. 269, amended by P.D. No. 1645, which governs the operations of electric cooperatives in the Philippines. The legal dispute arose out of Resolution No. 5 (Series of 2005) passed by the Board of Directors, which barred Seludo from attending board meetings and disqualified him from running for re-election.
Background of the Case
The conflict began when Seludo filed an Urgent Petition for Prohibition against SAMELCO II and its board members in the Regional Trial Court (RTC) of Calbiga, Samar, after the resolution was adopted. The RTC ruled in favor of Seludo by issuing a temporary restraining order against the enforcement of the resolution. The petitioners contended that the RTC lacked jurisdiction, asserting that the National Electrification Administration (NEA) held primary jurisdiction over matters involving electric cooperatives.
Court Actions and Decisions
The RTC confirmed its jurisdiction over the petition and denied the petitioners' motion for reconsideration. Subsequently, the petitioners escalated the matter to the Court of Appeals (CA), which ultimately dismissed their petition for certiorari, affirming the RTC’s orders. The CA maintained that the trial court had the jurisdiction to determine the issues raised in Seludo’s petition.
Arguments of the Petitioners
In their petition for review, the petitioners alleged several errors by the CA, primarily emphasizing issues concerning the doctrine of primary jurisdiction. They argued that the CA improperly limited the application of this doctrine and failed to recognize the NEA's authority under P.D. No. 1645 to determine the validity of the board resolutions affecting board members. Furthermore, they contended that Seludo had adequate remedies through the NEA and, therefore, the RTC's intervention was unwarranted.
Court’s Legal Reasoning
The Supreme Court evaluated the intertwined issues and concluded that while the RTC possessed jurisdiction over the petition for prohibition, the NEA maintained primary jurisdiction regarding the validity of SAMELCO II's board resolution. It cited the NEA’s expanded powers under P.D. No. 1645, emphasizing its role in exercising supervision and control over electric cooperatives, which included issuing orders pertinent to board resolutions.
Exhaustion of Administrative Remedies
The Court underscored the necessity for parties to exhaust all available administrati
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Case Overview
- This case is a petition for review on certiorari filed under Rule 45 of the Rules of Court.
- The petitioners include Samar II Electric Cooperative, Inc. (SAMELCO II) and its Board of Directors, while the respondent is Ananias D. Seludo, Jr.
- The Court of Appeals (CA) issued a Decision on January 26, 2006, dismissing the petition for certiorari and affirming the Orders of the Regional Trial Court (RTC) of Calbiga, Samar.
- The CA Resolution on July 12, 2006, denied the petitioners' Motion for Reconsideration.
Background
- SAMELCO II was organized under Presidential Decree No. 269, also known as the National Electrification Administration Decree, as amended by P.D. No. 1645.
- The individual petitioners are members of SAMELCO II's Board of Directors, while the respondent, Ananias D. Seludo, Jr., was also a director whose term expired in May 2005.
- On January 22, 2005, the Board passed Resolution No. 5, prohibiting Seludo from attending meetings and disqualifying him from running for re-election.
Procedural History
- Respondent Seludo filed an Urgent Petition for Prohibition against SAMELCO II and individual board members, seeking to nullify Resolution No. 5.
- The RTC granted a temporary restraining order (TRO) against the enforcement of the board resolution.
- Petitioners argued lack of jurisdiction, claiming that the NEA held primary jurisdiction over matters