Exhaustion doctrine of administrative remedies

The petitioner in this case became an employee of the Social Security System in 1985. In 1993, he applied for and took the Career Service Professional Examination of the Civil Service Commission. He passed this, which earned him a promotion to officership.

While he was promoted, an investigation was conducted on the veracity of the information he provided on the application. He was charged with five different infractions. Of the five, he was exonerated of four by the regional director of the Civil Service Commission. He filed for reconsideration, arguing that holding him liable for one charge was inconsistent with his exoneration from the other four. The regional director denied his motion.

This prompted him to go straight to the Court of Appeals. The appellate court dismissed his petition for non-exhaustion of administrative remedies. The court found the petition premature. His move to have the Court of Appeals reconsider its decision denied, he went up to the Supreme Court.

Here, the High Court discussed the doctrine of exhaustion of administrative remedies. It ruled: “Except as otherwise provided by the Constitution or by law, the Civil Service Commission shall have the final authority to pass upon the removal, separation, and suspension of all officers and employees in the civil service and upon all matters relating to the conduct, discipline, and efficiency of such officers and employees.

“As pointed out by the CA, pursuant to Section 5(A)(1) of MC 19, the Civil Service Commission Proper, or Commission Proper, shall have jurisdiction over decisions of Civil Service regional offices brought before it on petition for review. And under Section 43, ‘decisions of heads of departments, agencies, provinces, cities, municipalities and other instrumentalities imposing a penalty exceeding thirty days’ suspension or fine in an amount exceeding thirty days’ salary may be appealed to the Commission Proper within a period of fifteen days from receipt thereof.’

“‘Commission Proper’ refers to the Civil Service Commission-Central Office. It is only the decision of the Commission Proper that may be brought to the CA on petition for review, under Section 50 of MC 19, which provides thus: Section 50. Petition for Review with the Court of Appeals — A party may elevate a decision of the Commission before the Court of Appeals by way of a petition for review under Rule 43 of the 1997 Revised Rules of Court.

“Thus, we agree with the CA’s conclusion that in filing his petition for review directly with it from the CSC-CAR regional director, petitioner failed to observe the principle of exhaustion of administrative remedies. As correctly stated by the appellate court, non-exhaustion of administrative remedies renders petitioner’s CA petition premature and thus dismissible.

“The doctrine of exhaustion of administrative remedies requires that ‘before a party is allowed to seek the intervention of the court, he or she should have availed himself or herself of all the means of administrative processes afforded him or her.’

“Hence, if resort to a remedy within the administrative machinery can still be made by giving the administrative officer concerned every opportunity to decide on a matter that comes within his or her jurisdiction, then such remedy should be exhausted first before the court’s judicial power can be sought. The premature invocation of the intervention of the court is fatal to one’s cause of action. The doctrine of exhaustion of administrative remedies is based on practical and legal reasons. The availment of administrative remedy entails lesser expenses and provides for a speedier disposition of controversies.

“Furthermore, the courts of justice, for reasons of comity and convenience, will shy away from a dispute until the system of administrative redress has been completed and complied with, so as to give the administrative agency concerned every opportunity to correct its error and dispose of the case. Indeed, the administrative agency concerned — in this case the Commission Proper — is in the best position to correct any previous error committed in its forum.

“The CA is further justified in refusing to take cognizance of the petition for review, as ‘[t]he doctrine of primary jurisdiction does not warrant a court to arrogate unto itself the authority to resolve a controversy the jurisdiction over which is initially lodged with an administrative body of special competence. When petitioner’s recourse lies in an appeal to the Commission Proper in accordance with the procedure prescribed in MC 19, the CA may not be faulted for refusing to acknowledge petitioner before it.’”

The takeaway — always be mindful of availing yourself of remedies in an administrative body. Skipping those and seeking relief from the courts will only result in the dismissal of one’s cause, no matter how meritorious it may be.

The facts and the redacted portion of the quoted decision are from S.C. G.R. 191787 (22 June 2015).