Quasi-Judicial or Adjudicatory Power

Quasi-Judicial or Adjudicatory Power | Powers of Administrative Agencies | ADMINISTRATIVE LAW

Quasi-Judicial or Adjudicatory Power of Administrative Agencies

The quasi-judicial or adjudicatory power refers to the ability of administrative agencies to resolve disputes, determine rights, and impose liabilities similar to the functions of courts. This power is derived from statutes and granted to agencies so that they can make decisions that affect private parties in a manner that is typically judicial in nature, but within the specialized areas of administrative law. In the Philippines, the quasi-judicial powers of administrative agencies are recognized under the Constitution and various laws, and they are crucial in efficiently managing the increasing complexity of modern governance.

Key Aspects of Quasi-Judicial Powers of Administrative Agencies:

  1. Nature and Scope of Quasi-Judicial Power: Quasi-judicial power allows administrative agencies to hear and decide cases involving the rights and obligations of parties, often within their specialized areas of regulation. The agencies can issue orders, impose penalties, award damages, or grant relief based on the evidence and the law applicable to the dispute.

    These agencies are empowered to:

    • Conduct hearings
    • Issue subpoenas
    • Take evidence
    • Make findings of fact
    • Apply the law to these facts
    • Render binding decisions

    Their decisions are usually subject to judicial review, but courts generally defer to the agency’s expertise, especially in fact-finding and technical matters.

  2. Statutory Basis: Administrative agencies derive their quasi-judicial powers from enabling laws. These laws specify the scope and extent of the agency's authority. For example, the Labor Code grants the National Labor Relations Commission (NLRC) the authority to decide labor disputes, while the Securities Regulation Code gives the Securities and Exchange Commission (SEC) quasi-judicial powers over corporate disputes.

  3. Procedure in Exercising Quasi-Judicial Powers: The exercise of quasi-judicial powers typically follows procedures that mimic judicial proceedings. The Administrative Procedure Act (Republic Act No. 9485, also known as the Anti-Red Tape Act of 2007) and relevant rules of procedure of each agency guide the process. The parties are given notice and the opportunity to be heard (due process), and hearings are often conducted in a manner similar to court trials but with some flexibility in procedural requirements.

    The process generally includes:

    • Notice and Hearing: Before an agency can issue a decision affecting rights, it must provide notice to the parties and hold a hearing where both parties can present evidence.
    • Presentation of Evidence: Parties present their case through documents, testimonies, or other evidence. Agencies may also conduct their own investigations.
    • Fact-Finding and Legal Determination: The agency evaluates the evidence, makes findings of fact, and applies the relevant law.
    • Issuance of Decision: The agency issues a decision, which includes a statement of the facts, the applicable laws, and the rationale for the decision.
  4. Standards in the Exercise of Quasi-Judicial Powers:

    • Due Process: A fundamental requirement in the exercise of quasi-judicial power is that due process must be observed. This involves providing adequate notice and an opportunity to be heard, an impartial tribunal, and a decision based on substantial evidence.
    • Substantial Evidence Rule: In reviewing the factual findings of administrative agencies, courts apply the substantial evidence rule, which requires that the findings be supported by "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion." This is a lower standard than in criminal cases, where proof beyond reasonable doubt is required.
    • Judicial Deference: Courts typically afford administrative agencies a high level of deference, particularly in technical or specialized matters within their expertise. This deference is rooted in the understanding that administrative agencies are in a better position to assess and apply the specific regulatory framework governing their field.
  5. Review of Administrative Decisions: Decisions of administrative agencies are subject to judicial review, which ensures that administrative actions are within the bounds of law and comply with constitutional and statutory requirements. However, judicial review is limited to questions of law and jurisdiction. Courts do not interfere with an agency's factual findings unless there is grave abuse of discretion or a lack of substantial evidence.

    Under the Administrative Code of 1987, decisions of quasi-judicial agencies may be appealed to the Court of Appeals via Rule 43 of the Rules of Court, except in cases where a different mode of review is provided by law.

  6. Separation of Powers and Delegation: Quasi-judicial power is an exception to the doctrine of separation of powers. Administrative agencies, while part of the executive branch, are allowed to exercise judicial functions due to the necessity of resolving disputes that arise in the course of implementing their regulatory duties. This delegation is upheld by the courts provided that:

    • The agency acts within the scope of the authority granted by its enabling statute.
    • There are clear standards guiding the exercise of the quasi-judicial power to avoid an improper delegation of legislative or judicial authority.
  7. Examples of Agencies with Quasi-Judicial Powers: Numerous administrative agencies in the Philippines have quasi-judicial powers, each tailored to their respective mandates. Some prominent examples include:

    • National Labor Relations Commission (NLRC): Handles labor disputes between employers and employees.
    • Securities and Exchange Commission (SEC): Resolves corporate disputes, securities fraud, and issues relating to the regulation of corporations and the securities market.
    • Energy Regulatory Commission (ERC): Adjudicates matters related to the regulation of electricity rates and the energy industry.
    • Land Transportation Franchising and Regulatory Board (LTFRB): Decides on cases involving the operation of public transportation, such as granting franchises and resolving disputes between transport operators.
    • Civil Service Commission (CSC): Deals with administrative cases involving government employees.
  8. Principle of Exhaustion of Administrative Remedies: Before a party can bring an administrative case to court, the doctrine of exhaustion of administrative remedies generally requires that all available remedies within the administrative agency must first be pursued. This doctrine ensures that administrative agencies are given the opportunity to correct any mistakes and resolve disputes internally before judicial intervention. Failure to exhaust these remedies may result in the dismissal of a court case.

    Exceptions to this doctrine include:

    • When there is unreasonable delay in administrative proceedings.
    • When the issue involves purely legal questions.
    • When the administrative remedy is inadequate or ineffective.
    • When the agency has acted with grave abuse of discretion.
  9. Doctrine of Primary Jurisdiction: Related to the exhaustion doctrine is the doctrine of primary jurisdiction, which applies when a case requires the expertise of an administrative agency. Even if the matter could be heard by a court, the court will defer the case to the agency with specialized knowledge. This is particularly relevant in disputes involving regulatory laws and technical subject matter.

  10. Grave Abuse of Discretion: Administrative agencies must exercise their quasi-judicial powers without grave abuse of discretion. Grave abuse refers to a capricious or whimsical exercise of judgment amounting to an evasion of positive duty or a violation of law. When an administrative agency acts in such a manner, its decision may be annulled by a court through a petition for certiorari under Rule 65 of the Rules of Court.

Conclusion

The quasi-judicial or adjudicatory power of administrative agencies in the Philippines is an essential component of modern governance. It allows for the efficient resolution of disputes within specialized areas, reducing the burden on courts and providing expert decision-making. However, the exercise of this power is bounded by principles of due process, substantial evidence, judicial review, and the separation of powers. This ensures that while agencies may act in a quasi-judicial capacity, their actions remain accountable to the rule of law.

Administrative Res Judicata | Quasi-Judicial or Adjudicatory Power | Powers of Administrative Agencies | ADMINISTRATIVE LAW

Administrative Res Judicata: Quasi-Judicial Power in Administrative Agencies

1. Introduction to Administrative Res Judicata

Administrative Res Judicata refers to the application of the principle of res judicata in administrative proceedings. Res judicata, a concept traditionally rooted in judicial law, ensures finality in legal disputes by preventing the relitigation of matters already adjudicated. In administrative law, this principle is applied to quasi-judicial decisions rendered by administrative agencies, provided that certain requirements are met.

2. Quasi-Judicial or Adjudicatory Power of Administrative Agencies

Quasi-judicial power refers to the authority of administrative agencies to adjudicate disputes, make findings of fact, apply legal standards, and render decisions in a manner akin to courts. Unlike their rule-making (quasi-legislative) function, when agencies exercise quasi-judicial power, they resolve disputes between private parties or between private parties and the government. The decisions rendered by administrative agencies, in this regard, may be subject to the doctrine of res judicata.

3. Application of Res Judicata in Administrative Law

For the principle of res judicata to apply in administrative cases, the following requisites must be met:

  • Finality of Judgment: The decision or order of the administrative agency must be final and executory. It should not be subject to further administrative or judicial review, except on extraordinary grounds such as grave abuse of discretion.
  • Jurisdiction: The administrative agency must have acted within its legal authority or jurisdiction when rendering the decision.
  • Identity of Parties: The parties involved in the earlier administrative proceeding and the subsequent case must be the same or their privies.
  • Identity of Cause of Action: The cause of action, or the set of facts that gives rise to the dispute, must be the same in both proceedings.
  • Identity of Issues: The issues in the subsequent case must have been directly addressed and decided in the earlier administrative proceeding.

If these elements are satisfied, the doctrine of res judicata precludes the re-litigation of the same issues in a new case. It promotes the finality of administrative decisions, efficiency in the administrative process, and stability in legal relationships.

4. Types of Res Judicata in Administrative Proceedings

The application of res judicata in administrative law can take two forms:

  • Bar by Prior Judgment (Res Judicata in the Strict Sense): This prevents the re-litigation of a claim or cause of action that has been previously decided by an administrative body. If a final decision has been rendered on the merits of the case, the same parties are precluded from bringing a new case based on the same cause of action.

  • Conclusive Bar (Collateral Estoppel): Even if the second case is based on a different cause of action, res judicata bars the re-litigation of specific issues that were already adjudicated in a previous proceeding between the same parties. This means that once a particular issue has been determined by an administrative agency, it cannot be contested in a subsequent proceeding, even if the cause of action differs.

5. Limitations on the Application of Res Judicata

Although the principle of res judicata is applied in administrative proceedings, it is not applied as rigidly as in judicial cases. The following are some recognized limitations:

  • Public Interest Consideration: Administrative proceedings are often driven by public interest. Hence, where public policy or the interest of justice demands, the strict application of res judicata may be relaxed.
  • Discretion of Administrative Agencies: Courts typically afford deference to the expertise and discretion of administrative agencies, especially when the subject matter requires specialized knowledge. As such, in certain cases, agencies may reopen a matter if new facts arise that were not previously available or if there is a change in law or policy.
  • Non-Judicial Nature of Certain Proceedings: Not all administrative determinations are considered quasi-judicial. Some administrative acts are purely ministerial, and res judicata would not apply in those instances.

6. Judicial Review of Administrative Res Judicata

Decisions rendered by administrative agencies under the doctrine of res judicata may still be subject to judicial review under certain conditions. Courts may step in to correct:

  • Grave Abuse of Discretion: When the administrative agency is shown to have acted beyond its authority or with arbitrariness, courts may annul the decision even if res judicata is invoked.
  • Violation of Due Process: The denial of due process in administrative proceedings negates the application of res judicata. Parties must be given the opportunity to be heard and present evidence before res judicata can operate.
  • Fraud, Mistake, or Misrepresentation: A decision that was obtained through fraud or serious error may be set aside, thus precluding the application of res judicata.

7. Leading Philippine Jurisprudence on Administrative Res Judicata

The Supreme Court of the Philippines has addressed the issue of res judicata in administrative cases in several landmark decisions. Among these are:

  • Republic v. Oleta (G.R. No. 117513, July 17, 1997): The Court held that decisions of administrative bodies can attain finality and be covered by res judicata, similar to judicial decisions, provided that the requirements of jurisdiction, finality, and identity of issues and parties are met.

  • GSIS v. Court of Appeals (G.R. No. 121608, November 16, 2001): In this case, the Supreme Court emphasized that the principle of res judicata applies to administrative agencies exercising quasi-judicial powers, especially when a final decision on the merits has been rendered.

  • Ang Tibay v. CIR (G.R. No. L-46496, February 27, 1940): Although not directly addressing res judicata, this case is foundational in establishing the standards of due process in administrative proceedings. Without the observance of these principles, res judicata cannot apply.

8. Policy Considerations in Administrative Res Judicata

The application of res judicata in administrative cases balances the need for finality in administrative decisions with the flexibility needed in administrative adjudication. The policy considerations include:

  • Finality and Stability: Like in court proceedings, the application of res judicata in administrative adjudication aims to prevent endless litigation and fosters stability in administrative processes and decisions.
  • Efficiency: Res judicata promotes administrative efficiency by ensuring that once a matter is decided, it is not continuously re-litigated, thus conserving resources.
  • Flexibility and Justice: Despite its finality, the application of res judicata in administrative cases recognizes that administrative agencies, unlike courts, operate in a more flexible environment, where the correction of errors, pursuit of public interest, and consideration of new evidence can sometimes justify reopening a case.

9. Conclusion

The principle of administrative res judicata, when properly applied, plays a critical role in upholding the finality of decisions in the administrative adjudication process. However, given the unique nature of administrative law—where public policy and specialized agency functions are often at play—the application of this principle is adapted with some flexibility compared to judicial proceedings. It is essential that administrative bodies exercise their quasi-judicial functions in observance of due process and within the scope of their authority, as these elements are prerequisites to the successful application of res judicata.

Administrative Appeal and Review | Quasi-Judicial or Adjudicatory Power | Powers of Administrative Agencies | ADMINISTRATIVE LAW

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.

Administrative Due Process | Quasi-Judicial or Adjudicatory Power | Powers of Administrative Agencies | ADMINISTRATIVE LAW

POLITICAL LAW AND PUBLIC INTERNATIONAL LAW > XIII. ADMINISTRATIVE LAW > C. Powers of Administrative Agencies > 2. Quasi-Judicial or Adjudicatory Power > a. Administrative Due Process


Introduction to Administrative Due Process

Administrative due process refers to the procedural standards and protections afforded to individuals or entities in proceedings before administrative agencies exercising quasi-judicial or adjudicatory functions. These agencies are tasked with resolving disputes, interpreting laws, and issuing decisions affecting rights and obligations. Although these agencies do not operate like traditional courts, they are still required to observe fundamental principles of fairness and justice as enshrined in the Constitution.

In the Philippines, due process in administrative proceedings finds its basis in Article III, Section 1 of the 1987 Constitution, which states:

"No person shall be deprived of life, liberty, or property without due process of law, nor shall any person be denied the equal protection of the laws."

Administrative due process ensures that individuals or entities involved in such proceedings are provided with an opportunity to be heard and defend themselves before an impartial tribunal.


1. Nature of Quasi-Judicial or Adjudicatory Power of Administrative Agencies

Quasi-judicial power is the authority granted to administrative agencies to resolve disputes, make findings of fact, apply legal standards, and issue binding decisions or orders. When exercising these powers, agencies effectively perform functions similar to judicial bodies, hence the term "quasi-judicial."

Key Elements of Quasi-Judicial Power

  • Adjudication: Agencies determine rights, obligations, and liabilities through a formal or informal hearing process.
  • Issuance of Orders: Agencies can issue enforceable orders, decisions, or rulings that affect the parties involved.
  • Findings of Fact: Administrative agencies are tasked with determining the facts of the case based on evidence presented during the proceedings.
  • Application of Law: Agencies apply relevant laws, rules, and regulations to the facts of the case to arrive at a decision.

2. Requirements of Administrative Due Process

In the exercise of their quasi-judicial powers, administrative agencies must adhere to the requirements of administrative due process. The concept is rooted in both substantive and procedural due process principles:

Substantive Due Process:

Substantive due process ensures that the actions and decisions of administrative agencies are fair, reasonable, and not arbitrary. An agency's decision must be grounded on a legitimate government interest, supported by facts, and must not violate constitutional rights.

Procedural Due Process:

Procedural due process requires compliance with the following essential requisites:

  1. Right to Notice:

    • The party involved must be informed of the nature and cause of the accusation or action being taken against them.
    • Notice must be clear and specific, indicating the time, place, and nature of the hearing or proceeding.
    • Proper service of notice is required to ensure that the party is given a reasonable opportunity to prepare a defense or respond.
  2. Opportunity to be Heard:

    • The right to be heard is fundamental in administrative proceedings. The affected party must be given a fair chance to present their case, submit evidence, and argue their position.
    • In administrative hearings, the right to be heard does not necessarily require a full-blown trial-type proceeding. What is required is a reasonable opportunity to present one’s case.
    • Representation by counsel is generally allowed, but in some informal administrative proceedings, parties may represent themselves.
  3. Impartial Tribunal:

    • The decision-maker must be impartial and free from bias or conflict of interest. The tribunal must evaluate the evidence and arguments presented based on merits and law.
    • A biased or prejudiced decision-maker violates the requirement of fairness under due process.
    • Administrative officers or tribunals must adhere to the principle of "cold neutrality of an impartial judge."
  4. Consideration of Evidence:

    • The administrative agency must base its decision on substantial evidence presented during the proceedings. "Substantial evidence" refers to such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.
    • Decisions must not be based on mere conjecture or arbitrary considerations.
  5. Decision Rendered on the Merits:

    • The decision of the administrative agency must be based on the merits of the case, as established by the facts and the law.
    • The decision must clearly state the findings of fact, applicable law, and the reasons for the conclusion reached by the agency.
    • The decision must also be final, subject to any administrative appeals or judicial review, as provided by law.

3. The Due Process Standard in Administrative Proceedings

The standard of due process in administrative proceedings is more flexible and less formal than in judicial proceedings. In the case of Ang Tibay v. Court of Industrial Relations (G.R. No. 46496, February 27, 1940), the Philippine Supreme Court set forth the minimum due process standards applicable to administrative bodies, which have become known as the Ang Tibay Doctrine. The essential requirements of due process in administrative proceedings as articulated in Ang Tibay are:

  1. The right to a hearing: This includes the right to present one’s case and submit evidence.
  2. The tribunal must consider the evidence presented: The tribunal must evaluate and weigh the evidence submitted.
  3. The decision must be supported by evidence: The ruling must be grounded on substantial evidence that reasonably supports the decision.
  4. The decision must be rendered by an impartial tribunal: A neutral and unbiased tribunal must decide the case.
  5. There must be some evidence to support the tribunal’s findings: The decision should not be arbitrary but based on factual evidence presented in the case.
  6. The decision must be clear and definitive: The parties should be informed of the specific findings and rationale of the tribunal.
  7. The tribunal should act within its jurisdiction and authority: Administrative agencies must act within the scope of their granted powers.

4. Doctrine of Exhaustion of Administrative Remedies

Before a party can seek judicial intervention, the doctrine of exhaustion of administrative remedies requires that all administrative processes must first be completed. This doctrine upholds the principle that agencies should be given the opportunity to correct any errors or address grievances internally before court intervention is sought. Exceptions to this doctrine include cases where:

  • A pure question of law is involved.
  • The administrative remedy is inadequate or insufficient.
  • The agency acts with patent illegality or beyond its jurisdiction.
  • Immediate judicial intervention is necessary to prevent irreparable injury.
  • There is unreasonable delay or the administrative remedy is futile.

Failure to comply with the exhaustion of administrative remedies may result in the dismissal of the case for being premature.

5. Judicial Review of Administrative Decisions

Administrative agencies’ quasi-judicial decisions are generally subject to judicial review by the courts. However, such review is limited, and courts typically do not re-examine the factual findings of administrative agencies, provided that substantial evidence supports the findings. The courts primarily examine whether:

  • Due process was observed.
  • The decision was made within the scope of the agency’s authority.
  • The decision was supported by substantial evidence.
  • The decision was not tainted by grave abuse of discretion.

Conclusion

Administrative due process ensures fairness and protection of rights in the exercise of quasi-judicial powers by administrative agencies. While administrative proceedings are more flexible than judicial proceedings, the fundamental requirements of notice, the opportunity to be heard, an impartial tribunal, and a decision based on evidence remain essential components. These principles ensure that the rights of individuals are protected while allowing administrative agencies to effectively perform their adjudicatory functions.