Political and Public International Law › Administrative Law › Powers of Administrative Agencies

2. Quasi-judicial or Adjudicatory Power

Rendered in the exercise of quasi-judicial functions

  • Decisions, orders or rulings of the COMELEC or the COA may be brought on certiorari to the SC under Rule 64.
  • Decisions, orders or ruling of the CSC should be appealed to the CA under Rule 43.
  • A Rule 64 petition involving a COMELEC or COA judgment or final order must be filed within 30 days from notice, subject to Rule 64, Sec. 3 on a timely motion for reconsideration. An appeal from a CSC decision under Rule 43 must generally be filed within 15 days from notice of the decision or of the denial of a timely motion for reconsideration (Rule 43, Sec. 4).
  • Reconsideration is governed separately for each commission: COMELEC election cases are heard and decided in division, and motions for reconsideration of division decisions are decided by the commission en banc (Art. IX-C, Sec. 3, 1987 Constitution). For COA decisions, a timely motion for reconsideration is governed by Rule 64, Sec. 3. A motion for reconsideration is not an across-the-board prerequisite to a Rule 43 appeal from a final CSC decision; if a timely motion is filed, the appeal period runs from notice of its denial (Rule 43, Sec. 4).
  • The certiorari jurisdiction of the court is limited only to cases and matters rendered by a commission in the exercise of its adjudicatory power, or those relating to an election dispute and not to cases and matters purely administrative or executive in nature.

Necessity of Applicable Law

Before a tribunal, board, or officer may exercise judicial or quasi-judicial acts, it is necessary that there be a law that give rise to some specific rights of persons or property under which adverse claims to such rights are made, and the controversy ensuing therefrom is brought, in turn, before the tribunal, board or officer clothed with power and authority to determine what that law is and thereupon adjudicate the respective rights of the contending parties. (Santiago Jr. v. Bautista, G.R. No. L-25024, March 30, 1970).

Thus, an award of honors to a student by a board of teachers may not be reversed by a court where the awards are governed by no applicable law. (Id)

The court has no authority to entertain an action for judicial declaration of citizenship because there was no law authorizing such proceeding (Channie Tan v. Republic, G.R. No. L-14159, April 18, 1960).

Courts cannot reverse the award of a board of judges in an oratorical contest (Felipe v. Leuterio, G.R. No. L-4606, May 30, 1952).

Rendered in Exercise of Quasi-Judicial Functions

COA authority in Public Bidding

COA has the power to determine the meaning of ‘public bidding’ and what constitutes failure of the same when regulations require public bidding for the sale of government property.

Authorities

  • Chan v. Republic, G.R. No. L-14159, 18 April 1960
  • Felipe v. Leuterio, G.R. No. L-4606, 30 May 1952
  • Rule 43 (Rules of Court)
  • Rule 64 (Rules of Court)
  • Santiago v. Bautista, G.R. No. L-25024, 30 March 1970