XIII. ADMINISTRATIVE LAW

C. Powers of Administrative Agencies

2. Quasi-Judicial or Adjudicatory Power

b. Administrative Appeal and Review

Overview of Administrative Appeal and Review

Administrative agencies in the Philippines are vested with quasi-judicial or adjudicatory powers. These powers allow them to resolve disputes, hear cases, and make decisions within their specific areas of expertise. However, their decisions are subject to administrative appeal and review, which is a process through which a higher administrative authority or body re-examines the decisions of a lower administrative body or official. The objective is to ensure the correctness and legality of the decisions rendered.

1. Administrative Appeal

a. Definition and Nature

Administrative appeal refers to the procedure by which a party aggrieved by a decision of an administrative agency may seek redress by appealing to a higher administrative authority. It is a process of intra-agency review, meaning the appeal stays within the administrative structure, without immediately resorting to judicial courts.

b. Who May Appeal

Typically, any party to the case who is adversely affected by the decision of the administrative agency may appeal. This includes:

Parties to the original proceedings (complainant or respondent),
Any other person who may have been allowed to intervene in the case, or
A third-party whose rights may be directly affected by the decision.

c. Authority to Appeal

The governing statutes or regulations of the agency involved usually establish the administrative appellate process.
The power to appeal depends on the enabling law of the administrative body and the agency's own procedural rules.

d. When an Appeal is Available

The availability of an appeal depends on the agency's enabling act or specific law governing the agency. Typically, appeals must be filed within a prescribed period, which may vary across agencies. Failure to file within this period may result in the dismissal of the appeal.

e. Nature of Administrative Appeals

Administrative appeals are generally non-litigious and informal, but they are not devoid of legal rules and procedures. Some characteristics include:

Ex parte nature: Administrative appeals are often decided without formal hearings.
De novo nature: The appellate authority may conduct a full review of both factual and legal issues.
Limited to the record: In some instances, the appellate authority reviews the case based on the evidence presented in the initial adjudication.

f. Grounds for Appeal

Common grounds for appeal in administrative adjudications include:

Errors of fact or law,
Grave abuse of discretion,
Decisions that are arbitrary or capricious,
Violations of due process,
Misapplication or misinterpretation of laws.

2. Administrative Review

a. Definition and Nature

Administrative review is broader than an appeal and refers to the process wherein a superior administrative body re-examines, motu proprio or upon request, the decisions of a subordinate agency. The review may occur as part of the agency's internal mechanism for ensuring the uniformity and correctness of its decisions.

b. Types of Review

Mandatory Review: Some decisions are automatically subject to review by a higher authority, such as those involving significant public interest.
Discretionary Review: In other cases, the review is discretionary and depends on whether the reviewing authority finds merit in examining the decision further.

c. Scope of Review

Administrative review can cover:

Factual findings: Higher authorities may re-evaluate evidence and ascertain if facts were correctly determined.
Legal conclusions: It can involve a re-assessment of the legal principles applied by the lower administrative body.
Procedural matters: Administrative reviews may also consider whether due process was followed.

3. Hierarchy of Administrative Appeals and Review

a. Appeal within the Agency

Decisions of lower administrative officials or bodies can often be appealed to their respective higher offices or boards within the same agency. For example:

The decision of a Regional Director of an administrative agency may be appealed to the Secretary or a higher administrative tribunal within the same department.

b. Inter-Agency Appeals

Some administrative decisions may be appealed to another administrative body, such as:

Civil Service Commission (CSC) for issues related to civil service employees,
Commission on Audit (COA) for issues relating to government expenditures.

c. Administrative Courts or Tribunals

Certain specialized tribunals serve as appellate bodies for administrative cases. For instance:

National Labor Relations Commission (NLRC) for labor disputes,
Board of Energy (now Energy Regulatory Commission) for energy-related disputes.

d. Judicial Review as a Last Resort

Once all administrative remedies have been exhausted, aggrieved parties may elevate the matter to the judicial courts via a petition for review. Under the doctrine of exhaustion of administrative remedies, courts will only entertain a case if the aggrieved party has fully pursued all administrative appeals or reviews available.

4. Doctrine of Exhaustion of Administrative Remedies

a. Principle

The doctrine of exhaustion of administrative remedies mandates that before a party can seek judicial intervention, they must first exhaust all remedies within the administrative framework. This doctrine is based on the following justifications:

To give administrative agencies the opportunity to correct errors,
To allow agencies to apply their expertise,
To lessen the burden on courts,
To promote judicial economy.

b. Exceptions to the Doctrine

There are recognized exceptions to the doctrine, including:

If the issue involves a purely legal question, the party may go directly to the courts.
If irreparable injury would result from pursuing administrative remedies.
If there is grave abuse of discretion on the part of the administrative agency.
If the administrative remedies are inadequate or futile.
When the issue raised involves a constitutional question.

5. Judicial Review of Administrative Decisions

a. Nature of Judicial Review

Once the administrative appeal process is exhausted, judicial review of administrative decisions may be sought. The courts' review is usually limited to:

Questions of law rather than factual issues.
Determining whether the agency acted within its jurisdiction or authority.
Examining whether there was grave abuse of discretion amounting to lack or excess of jurisdiction.

b. Standards of Review

Courts generally accord great deference to the factual findings of administrative agencies, given their expertise in their respective fields. The court will not interfere with the agency's decisions unless:

The decision is tainted with grave abuse of discretion,
The agency violated the Constitution or acted beyond its powers,
There is no substantial evidence to support the decision.

c. Modes of Judicial Review

Judicial review of administrative decisions is typically initiated through the filing of a:

Petition for Certiorari under Rule 65 of the Rules of Court, in cases involving grave abuse of discretion,
Petition for Review under Rule 43, which covers appeals from quasi-judicial agencies to the Court of Appeals.

Conclusion

The administrative appeal and review process is essential for ensuring that administrative agencies exercise their quasi-judicial powers fairly, correctly, and within the bounds of their authority. By providing a system for intra-agency review and judicial oversight, this mechanism helps safeguard the rights of parties while promoting the efficient and expert resolution of administrative disputes. However, the appeal process is not open-ended; aggrieved parties must follow procedural rules, respect administrative hierarchies, and exhaust remedies before seeking judicial intervention.