G.R. No. 113357; February 1, 1996
BENJAMIN PAREDES, et al., petitioners, vs. COURT OF APPEALS, RIZALINO S. NAVARRO, as Secretary of Trade and Industry, and IGNACIO S. SAPAL, Director of the Bureau of Patents, Trademarks and Technology Transfer, respondents.

FACTS

On November 9, 1992, public respondents promulgated Administrative Order Nos. 1 and 2, Series of 1992, revising the rules of practice before the Bureau of Patents, Trademarks and Technology Transfer (BPTTT). The orders, set to take effect on March 15, 1993, included provisions increasing fees for patent and trademark registration and prohibiting the filing of multi-class applications. On March 11, 1993, petitioners, who are registered patent agents, filed a Petition for Prohibition with the Court of Appeals. They sought to enjoin the enforcement of these orders and to declare specific rules null and void, primarily arguing that the orders were invalid for non-compliance with the publication requirements under the Administrative Code and B.P. Blg. 325.
The Court of Appeals dismissed the petition on October 27, 1993, and denied reconsideration on January 10, 1994. The appellate court held that petitioners failed to exhaust administrative remedies, as the enabling law, B.P. Blg. 325, provided a specific process requiring Cabinet approval for revised fees. Petitioners then elevated the case to the Supreme Court via certiorari, reiterating their claims regarding the invalidity of the orders for lack of proper publication and for amending the Trademark Law without authority.

ISSUE

Whether the Court of Appeals erred in dismissing the petition for prohibition on the ground of non-exhaustion of administrative remedies.

RULING

The Supreme Court denied the petition and affirmed the dismissal. The Court ruled that prohibition was not the proper remedy because petitioners failed to exhaust the administrative remedies expressly provided by law. B.P. Blg. 325, which authorized the revision of fees, established a specific three-step process: recommendation by the BPTTT, evaluation and approval by the Department of Trade and Industry Secretary in conformity with Ministry of Finance rules, and final approval by the Cabinet. The law mandated that the revised rates were “subject to the approval of the Cabinet,” indicating a built-in administrative review mechanism.
The Court emphasized that the doctrine of exhaustion of administrative remedies is fundamental. Where the enabling statute provides a system of administrative appeal or reconsideration, courts will not entertain a case unless these available remedies have been resorted to, giving the appropriate authorities the opportunity to correct errors. Prohibition is an extraordinary writ granted only when no other sufficient remedy is available. Since B.P. Blg. 325 provided a clear administrative path for challenging the fee revisions—by seeking or challenging Cabinet approval—petitioners’ direct recourse to the courts was premature. Judicial review should follow the completion of the administrative process.