G.R. No. 100579 ; June 6, 2001
LEANDRO P. GARCIA, petitioner, vs. THE HONORABLE COURT OF APPEALS, THE PHILIPPINE COCONUT AUTHORITY GOVERNING BOARD, and JOSEFEL P. GRAJEDA, respondents.

FACTS

On October 18, 1988, the PCA Governing Board passed Resolution No. 109-88, creating an Investigation Committee to look into a complaint by Antonio Pua against petitioner Leandro P. Garcia, then PCA Administrator. The Board amended the committee’s composition on February 7 and 14, 1989. On February 28, 1989, the Investigation Committee submitted its findings, recommending the filing of formal charges against Garcia for dishonesty, falsification, grave misconduct, and violation of R.A. No. 3019 , and that he be placed under preventive suspension. On March 1, 1989, the PCA filed an administrative complaint (Special PCA Administrative Case No. 01-89) against Garcia. The Board, pursuant to its Resolution No. 021-89, placed Garcia under preventive suspension effective March 6, 1989. Garcia, through counsel, requested and was granted extensions to file his answer. Hearings were scheduled, but Garcia and his counsel repeatedly failed to appear despite notice, leading to postponements. On May 30, 1989, the Board issued Resolution No. 046-89, ruling that the period of delay caused by Garcia’s requests for extension and postponement would not be counted in computing the 90-day period of preventive suspension under P.D. No. 807 (Civil Service Law). On June 7, 1989, Garcia filed a petition for certiorari, mandamus, and prohibition with the RTC of Quezon City, seeking to enjoin the implementation of Resolution No. 046-89 and the proceedings of the Investigation Committee. The RTC issued a status quo order and later a writ of preliminary injunction restraining the Board from implementing Resolution No. 046-89. The Court of Appeals set aside the RTC orders. Garcia filed a petition for review with the Supreme Court.

ISSUE

Whether the Court of Appeals erred in setting aside the orders of the Regional Trial Court, which had issued a writ of preliminary injunction against the implementation of the PCA Board’s resolution extending Garcia’s preventive suspension beyond the 90-day period prescribed by P.D. No. 807, on the ground that Garcia failed to exhaust administrative remedies.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the doctrine of exhaustion of administrative remedies was applicable and mandatory in this case. Garcia’s failure to participate in the administrative hearings despite due notice and his subsequent resort to judicial intervention without allowing the administrative process to be completed constituted a failure to exhaust administrative remedies. The Court found that Garcia had effectively delayed the resolution of the administrative case through repeated requests for extension and inexcusable refusal to attend scheduled hearings. The Court emphasized that the observance of the exhaustion doctrine insures an orderly procedure and withholds judicial interference until the administrative process has duly run its course. The Court also noted that the 90-day preventive suspension period under Section 42 of P.D. No. 807 could be extended if the delay in the disposition of the case was due to the fault, negligence, or petition of the respondent, as was the situation with Garcia’s actions. Therefore, the Court of Appeals correctly set aside the RTC’s orders for having been issued in grave abuse of discretion.