G.R. No. L-47821 September 15, 1988
BENITO ROSALES, EMILIA R. ROSALES and ROMMEL ROSALES represented by Guardian-Ad-Litem, ROMMEL ROSALES, petitioners, vs. COURT OF APPEALS and DON BOSCO TECHNICAL INSTITUTE, FR. AGUSTIN LOPEZ; MRS. S.A. MENDOZA, assisted by her husband GODOFREDO MENDOZA and MISS FELICIDAD GORDON, respondents.

FACTS

Petitioners, the parents of student Rommel Rosales, filed a complaint for damages against Don Bosco Technical Institute. They alleged that Rommel was unjustly deprived of being the class valedictorian due to an anomalous ranking of honor pupils. They first sought administrative relief by filing a complaint with the Director of Private Schools, who ruled in their favor on May 5, 1972, declaring Rommel the rightful valedictorian. However, the school filed a motion for reconsideration. Subsequently, on December 18, 1972, the Director reconsidered and set aside his initial decision, instead approving the school’s selection of honors.
Despite the pendency of further administrative appeals, petitioners filed a civil case for damages in the trial court on November 29, 1972. The records show that after the Director’s reconsideration, petitioners themselves filed a motion for reconsideration on January 11, 1973, which was denied. They then appealed to the Secretary of Education on February 7, 1973. This appeal was still unresolved when they initiated the court action.

ISSUE

Whether the trial court correctly dismissed the complaint for damages on the ground of failure to exhaust administrative remedies.

RULING

Yes. The Supreme Court affirmed the dismissal. The doctrine of exhaustion of administrative remedies mandates that recourse to judicial action cannot generally prosper until all remedies within the administrative machinery have been availed of and exhausted. The Court found that petitioners’ cause of action for damages was inherently premature because it was predicated on a final administrative determination of the valedictorian issue, which did not yet exist.
At the time the civil complaint was filed, the administrative process was ongoing. The initial decision of the Director of Private Schools dated May 5, 1972, had been reconsidered. Petitioners had subsequently appealed to the Secretary of Education, and that appeal was still pending resolution. Since the administrative case giving life to their claim for damages was not yet final, the judicial action had no proper basis. The Court also rejected the claim of denial of due process, noting that petitioners were afforded and did utilize administrative remedies, including filing a motion for reconsideration and an appeal, which are curative of any procedural defect. Therefore, the trial court and the Court of Appeals committed no error in dismissing the complaint for failure to exhaust administrative remedies.