XIII. Administrative Law

Administrative Law is the branch of public law that governs the activities and operations of administrative agencies of the government. It encompasses the organization, functions, powers, and procedures of administrative bodies, as well as the remedies available to parties affected by administrative actions. In the context of the Philippines, Administrative Law has deep constitutional and statutory foundations, integrating doctrines of due process, rule of law, and the administrative independence of agencies.

Key Principles and Doctrines in Administrative Law

Doctrine of Delegation
Administrative law is largely built on the principle of delegation, wherein legislative powers are delegated to administrative agencies. This doctrine allows Congress to delegate the implementation and enforcement of its laws to specialized administrative bodies that can fill in the details through rule-making and adjudication. However, this delegation must adhere to certain limits:
- Sufficient Standard Test – Congress must provide a clear policy or standard to guide the administrative body’s actions.
- Completeness Test – The law delegating the power must be complete in all its essential terms and conditions.
Administrative Agencies
These are government bodies tasked with the execution and enforcement of specific statutes or regulatory frameworks. They operate with quasi-legislative (rule-making), quasi-judicial (adjudication), and executive (enforcement) powers, making them unique from other government entities. Examples in the Philippines include the Securities and Exchange Commission (SEC), Energy Regulatory Commission (ERC), National Telecommunications Commission (NTC), and Land Transportation Office (LTO).
- Quasi-Legislative Power: This refers to the power to issue rules and regulations to carry out legislative policies. These rules, when validly promulgated, have the force and effect of law.
  - Requisites for Valid Rule-Making:
    1. The agency must act within the scope of its authority.
    2. The regulation must be issued in accordance with the prescribed procedure (including publication and consultation when required).
    3. The rule must be reasonable and consistent with the law it intends to implement.
- Quasi-Judicial Power: Administrative agencies can also resolve disputes, issue orders, and impose penalties. This quasi-judicial power is usually exercised in specialized fields (e.g., labor disputes under the National Labor Relations Commission (NLRC)).
  - Administrative Due Process: In exercising their adjudicative functions, administrative agencies must observe due process. The essentials of administrative due process include:
    1. Right to Notice: Parties must be notified of the charges or the nature of the case.
    2. Opportunity to Be Heard: Parties must be given the opportunity to present their case.
    3. Evidence: Decisions must be based on substantial evidence presented before the agency.
    4. Impartial Tribunal: The decision-maker must not have a conflict of interest or bias.
    5. Right to a Reasoned Decision: The decision must clearly state the facts, laws, and reasoning that led to the conclusion.
- Executive Functions: These include the enforcement of regulations, supervision of regulated entities, and administrative operations, such as issuing permits and licenses.
Judicial Review of Administrative Actions Administrative actions, whether quasi-legislative, quasi-judicial, or executive in nature, are subject to judicial review to ensure legality, propriety, and fairness.
- Grounds for Judicial Review:
  1. Lack or Excess of Jurisdiction: The agency acted beyond its legal authority.
  2. Grave Abuse of Discretion: The agency acted in an arbitrary or capricious manner.
  3. Violation of Due Process: The administrative body failed to follow the procedural and substantive requirements of due process.
  4. Error of Law: The agency misapplied or misconstrued the law.
  5. Lack of Substantial Evidence: The decision is not supported by substantial evidence in the record.
- Doctrine of Exhaustion of Administrative Remedies: Before a party can seek judicial review, it must first exhaust all available remedies within the administrative agency. This doctrine aims to:
  1. Allow the agency to correct its own errors.
  2. Relieve courts of the burden of reviewing administrative cases prematurely.
  3. Ensure that administrative expertise is first applied to the matter.
Exceptions to the Doctrine:
1. The issue involves a purely legal question.
2. The administrative remedy is inadequate or ineffective.
3. The agency has acted with grave abuse of discretion.
4. There is irreparable harm or injury.
- Doctrine of Primary Jurisdiction: When a case involves a matter that falls within the special competence of an administrative agency, courts should defer to the agency for its expertise in resolving the matter. This doctrine promotes the efficient resolution of specialized disputes.
- Finality of Administrative Decisions: Administrative decisions, once final, cannot be overturned unless the courts find that the agency acted without or in excess of jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction.
Administrative Investigations and Hearings Administrative bodies can conduct investigations into violations of laws and regulations within their jurisdiction. These investigations can lead to sanctions such as fines, suspensions, or cancellations of permits.
- Procedure: Investigations generally begin with the filing of a complaint, followed by a preliminary inquiry. A formal hearing may be held, after which the agency will issue a decision. The rules of evidence in administrative proceedings are generally relaxed compared to judicial proceedings.
- Substantial Evidence Rule: In administrative cases, decisions must be based on "substantial evidence" – evidence that a reasonable mind might accept as adequate to support a conclusion. This is a lower standard than in criminal or civil cases, where "proof beyond reasonable doubt" or "preponderance of evidence" is required.
Administrative Appeals and Remedies Parties aggrieved by an administrative decision can usually seek a reconsideration or appeal within the agency itself. If they remain unsatisfied, they may elevate the case to a higher administrative authority or seek judicial review.
- Motion for Reconsideration: This is a common remedy within administrative agencies, which allows the losing party to request the agency to re-evaluate its decision.
- Appeal to Higher Authorities: In some cases, the law provides for appeals from the decision of a lower administrative agency to a higher one, or directly to the President of the Philippines.
- Judicial Review by Courts: As mentioned earlier, parties may also seek judicial review of administrative actions through a Petition for Certiorari under Rule 65 of the Rules of Court, alleging grave abuse of discretion.
Doctrine of Administrative Res Judicata
When an administrative body has rendered a final decision on the merits of a case, that decision can have the effect of res judicata, meaning that the matter cannot be relitigated in another forum. This doctrine ensures the finality of administrative decisions and promotes judicial economy.
Public Policy and Public Interest Considerations Administrative agencies are often tasked with protecting public welfare and upholding the public interest in the regulatory areas under their control. Their actions are presumed to be in good faith and are typically accorded a presumption of regularity. However, this presumption can be rebutted by clear evidence of irregularities, illegal actions, or grave abuse of discretion.
Freedom of Information and Administrative Transparency Under Executive Order No. 2, s. 2016, the Philippine government adopted the Freedom of Information (FOI) policy, which enhances transparency by granting citizens the right to access government documents, including those held by administrative agencies. This is subject to certain limitations (e.g., national security, privacy concerns, etc.).
Liability of Public Officers in Administrative Bodies Public officers in administrative agencies can be held administratively, civilly, or criminally liable for acts performed in the exercise of their duties. The Administrative Code of 1987 and Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees) govern the conduct of public officers and provide for disciplinary actions for violations of their duties.

In conclusion, Administrative Law in the Philippines ensures the effective implementation and enforcement of laws by administrative agencies while providing mechanisms to check and balance these powers. It is crucial for protecting the rights of individuals while ensuring that the state's regulatory needs are met efficiently and fairly. Judicial oversight, principles of due process, and doctrines like exhaustion of administrative remedies ensure that administrative actions are just, reasonable, and within the bounds of law.