PRINCIPLE OF JUDICIAL HIERARCHY IN THE PHILIPPINE JUDICIARY

1. OVERVIEW OF THE PHILIPPINE JUDICIAL SYSTEM

Before delving into the principle of hierarchy of courts, it is crucial to understand the structure of the Philippine judiciary. The judiciary is composed of the following courts, arranged from highest to lowest in authority:

Supreme Court – The highest court of the land, created by the 1987 Constitution. It has both appellate and original jurisdiction in particular cases (e.g., cases involving the constitutionality of certain acts, petitions for certiorari, prohibition, mandamus, quo warranto, and habeas corpus).
Court of Appeals – An appellate court that generally reviews decisions, orders, or resolutions of Regional Trial Courts (RTCs), quasi-judicial agencies (in certain instances), and sometimes the decisions of other lower courts. The Court of Appeals is stationed in Manila, with divisions in Cebu and Cagayan de Oro.
Sandiganbayan – A special appellate court with jurisdiction over criminal and civil cases involving graft and corruption and other offenses committed by public officers and employees under its jurisdiction, as defined by law.
Court of Tax Appeals – A special appellate court that has jurisdiction over tax-related controversies, customs matters, and cases involving decisions of the Commissioner of Internal Revenue or the Commissioner of Customs.
Regional Trial Courts (RTCs) – Courts of general jurisdiction in civil, criminal, and other cases that are not exclusively within the jurisdiction of specialized courts. They are spread throughout the judicial regions of the country.
Metropolitan Trial Courts (MeTCs), Municipal Trial Courts in Cities (MTCCs), Municipal Trial Courts (MTCs), and Municipal Circuit Trial Courts (MCTCs) – Lower courts that handle specific matters (mostly minor criminal offenses, civil cases involving smaller sums, and violations of local ordinances).

This hierarchy of courts is carefully set in place to promote efficiency, organization, and the orderly dispensation of justice.

2. DEFINITION AND ESSENCE OF THE PRINCIPLE OF JUDICIAL HIERARCHY

The principle (or doctrine) of judicial hierarchy is a procedural rule that requires litigants to file or bring their cases, whether civil, criminal, or special proceedings, in the lowest court of competent jurisdiction appropriate for the remedy they seek. As a general rule, parties must first seek relief in the lower courts before elevating their case to the next higher court.

Reasons for the Doctrine:

Prevent Overcrowding of Dockets in Higher Courts – By requiring parties to approach the lower courts first, the Supreme Court and other higher courts can devote more time to significant questions of law or to novel and important constitutional issues.
Ensure the Development of the Factual Record – Lower courts are better positioned to conduct trials, receive evidence, and resolve factual issues. The higher courts primarily function to resolve questions of law or to review possible errors committed below.
Maintain Order and Efficiency – The judicial hierarchy ensures smooth and efficient operation of the judiciary by delegating disputes initially to courts designed to handle them.
Expertise and Specialization – Some courts have specialized jurisdictions (e.g., family courts, commercial courts, environmental courts, tax courts), and the principle of hierarchy recognizes that these courts can handle specific matters more effectively.

3. THE GENERAL RULE: FILE IN THE APPROPRIATE LOWER COURT FIRST

As a general rule, litigants must observe the following flow:

Municipal/Metropolitan/City Trial Courts → Regional Trial Courts → Court of Appeals → Supreme Court

In special cases:

Specialized courts like the Sandiganbayan or Court of Tax Appeals also function at the level of the Court of Appeals in a certain sense (i.e., they are collegiate courts with specialized jurisdiction). Once their decisions are final and appealable, the next step is usually the Supreme Court or the Court of Appeals, depending on the subject matter and statutory provisions.

This standard route prevents a party from “skipping” directly to the Supreme Court or the Court of Appeals, unless exceptions apply.

4. EXCEPTIONS TO THE PRINCIPLE OF HIERARCHY OF COURTS

While the principle of hierarchy of courts is firmly established, it is not an absolute or inflexible rule. Jurisprudence and procedural rules recognize certain exceptions where a higher court may directly be approached. Some common exceptions include:

Direct Invocation of the Supreme Court’s Original Jurisdiction in Exceptional Cases
- The Supreme Court has original jurisdiction over petitions for certiorari, prohibition, mandamus, quo warranto, and habeas corpus under the Constitution.
- In some extraordinary instances involving constitutional questions, issues of transcendental importance, or compelling time constraints, litigants may directly petition the Supreme Court even if a lower court also has concurrent jurisdiction.
Questions of Novel or Transcendental Importance
- When issues presented are of paramount public interest or involve a significant constitutional question, the Supreme Court may exercise its discretionary power to take cognizance of the matter directly in order to promptly settle the important constitutional or legal question.
Avoiding a Delay That Would Result in Grave Injustice
- If going through the lower courts would cause a significant delay that might defeat the ends of justice, direct recourse to a higher court can be justified. For instance, if the issue is so urgent (e.g., risk of irreparable harm or violation of a fundamental right), the higher court may allow a bypass of the lower courts.
When the Lower Courts Are Incapable of Acting
- In scenarios where the lower courts cannot act because of certain disabilities, bias, or other unique circumstances, direct resort to a higher court may be permitted.
Cases Where the Supreme Court Exercises Its Power of Judicial Supervision
- The Supreme Court, as the court of last resort, has supervisory powers over lower courts. If an urgent matter relates to the power of the Supreme Court to control and supervise lower courts, the principle of judicial hierarchy may be relaxed.

It is important to note that directly filing with a higher court when there is no justifiable exception can lead to a dismissal of the action or petition based on violation of the rule on hierarchy of courts. Thus, the party must convincingly demonstrate the presence of any recognized exception.

5. RELEVANT JURISPRUDENCE

Several Supreme Court rulings have elucidated the principle of judicial hierarchy:

People v. Cuaresma (172 SCRA 415)
- The Supreme Court held that where the issuance of extraordinary writs is concurrently vested in the RTC, Court of Appeals, and Supreme Court, the petitioner should first seek recourse in the lower courts. The High Court is not a trier of facts, and the principle of hierarchy of courts must be respected.
Santiago v. Vasquez (217 SCRA 633)
- The Court reiterated that although the Supreme Court has concurrent jurisdiction with the RTC and the Court of Appeals to issue writs of certiorari, direct resort to the highest tribunal should be allowed only in exceptionally compelling reasons involving questions of constitutionality, issues of national interest, or cases of first impression.
Heirs of Hinog v. Melicor (455 SCRA 460)
- The Court stressed that the principle of hierarchy of courts is a practical judicial policy designed to restrain litigants from directly resorting to the Supreme Court unless the redress sought cannot be obtained in the appropriate courts.

These and other cases highlight the Court’s consistent stance in upholding the principle of judicial hierarchy, as it prevents the undue clogging of appellate dockets.

6. LEGAL BASIS AND RULES

Constitutional Provisions
- Article VIII, Section 5 of the 1987 Constitution vests the Supreme Court with original jurisdiction over certain extraordinary writs and appellate jurisdiction over final judgments of lower courts. However, it does not imply exclusive or automatic preference for a direct filing with the Supreme Court. Lower courts share concurrent jurisdiction over writs of certiorari, prohibition, and mandamus.
Rules of Court
- Under Rule 65 of the Rules of Court, petitions for certiorari, prohibition, and mandamus may be filed in the RTC, the Court of Appeals, the Sandiganbayan, or the Supreme Court, depending on which court has jurisdiction over the principal action. The general rule is to file such petitions in the lower court unless compelling exceptions justify otherwise.
Supreme Court Circulars
- The Supreme Court has issued administrative circulars and guidelines that underscore the necessity of following the hierarchy of courts to avoid undue crowding of Supreme Court dockets.

7. IMPLICATIONS OF NON-COMPLIANCE

Failure to observe the judicial hierarchy can lead to:

Dismissal of the Petition or Action
- If a petition is filed directly with the Supreme Court without showing any special or compelling reason for deviating from the hierarchy, the petition may be dismissed outright.
Wasted Time and Resources
- Litigants lose valuable time and resources if the higher court dismisses the case for non-compliance and the case must be re-filed at the correct level.
Possible Waiver of Rights or Remedies
- Delays in securing the correct remedy because of procedural missteps could prejudice a party’s position, including prescriptive periods and other procedural timelines.

8. SUMMARY AND BEST PRACTICES

Always File at the Lowest Level of Competent Jurisdiction First
Determine which court has jurisdiction over your case based on the nature of the action or relief sought, and file at that level unless there is a clear, justifiable exception.
State Grounds for Direct Recourse to a Higher Court
If a litigant decides to elevate the matter immediately to the Supreme Court or the Court of Appeals, the petition must clearly set out compelling reasons for doing so (e.g., transcendental importance, urgent necessity, overriding public interest, or irreparable damage).
Observe Procedural Requirements
Ensure strict compliance with procedural rules: payment of docket fees, correct form of pleadings, proper verification, certification against forum shopping, and timely filing.
Consult Relevant Case Law
The Supreme Court’s pronouncements guide when deviations from the hierarchy are permissible. Carefully cite and rely on precedents if you must bypass the lower courts.
Emphasize Factual Record
Recognize that the Supreme Court is not a trier of facts. If the case involves complex factual issues, be prepared to litigate at the trial court level.

9. CONCLUSION

The principle of judicial hierarchy is foundational to the Philippine legal system’s orderly administration of justice. While the Constitution and the Rules of Court grant concurrent jurisdiction to different courts for certain remedies, litigants must observe the rule that, as a general policy, those remedies should be sought initially in the lower courts. Direct recourse to the Supreme Court or a higher court is not a matter of right; it is the exception that must be justified by compelling circumstances such as transcendental importance, constitutional necessity, or grave and irreparable injury otherwise left without immediate remedy.

Understanding and adhering to this doctrine ensures that the appellate courts, especially the Supreme Court, can focus on significant questions of law and maintain their proper role as the final arbiter of disputes.