G.R. No. 166923 , November 26, 2014.
PHILIPPINE MIGRANTS RIGHTS WATCH, INC., on its own behalf and on behalf of its member overseas Filipino workers, JESUS REYES and RODOLFO MACOROL, Petitioners, vs. OVERSEAS WELFARE WORKERS ADMINISTRATION and its Board of Trustees composed of HON. PATRICIA A. STO. TOMAS, VIRGILIO R. ANGELO, MANUEL G. IMSON, The Secretary of Foreign Affairs, represented by Undersecretary JOSE S. BRILLANTES, ROSALINDA BALDOZ, The Secretary of Budget and Management, represented by Assistant Secretary EDUARDO P. OPIDA, MINA C. FIGUEROA, VICTORINO F. BALAIS, CAROLINE R. ROGGE, GREGORIO S. OCA, CORAZON P. CARSOLA and VIRGINIA J. PASALO, Respondents.

FACTS

On September 19, 2003, respondent Overseas Workers Welfare Administration (OWWA) issued Board Resolution No. 038, the “OWWA Omnibus Policies.” On February 18, 2004, petitioners filed a Complaint before the Regional Trial Court (RTC) of Pasay City seeking to annul specific provisions of the Omnibus Policies. Petitioners alleged that the policies acted with grave abuse of discretion, were contrary to the Constitution and its enabling laws, and violated the Equal Protection Clause by limiting OWWA benefits only to member-contributors who paid a US$25.00 membership contribution per contract, a fee originally charged to employers. Petitioners also assailed provisions allowing OWWA Board members to designate voting proxies and classifying Board documents as confidential. The RTC, in an Order dated August 31, 2004, dismissed the complaint for lack of jurisdiction, ruling that the determination of the constitutionality of the assailed resolution rested with the Supreme Court and that the appropriate remedy was a special civil action for certiorari under Rule 65. Petitioners filed a petition for review directly with the Supreme Court.

ISSUE

Whether the Regional Trial Court committed reversible error in dismissing the complaint (Civil Case No. 04-0077) on the ground of lack of jurisdiction over a case challenging the constitutionality of an administrative issuance (the OWWA Omnibus Policies).

RULING

Yes. The Supreme Court ruled in favor of the petitioners. The Court held that Regional Trial Courts have original jurisdiction to hear and decide cases involving the constitutionality or validity of administrative rules and regulations. The RTC’s reliance on the case of Fortich v. Corona was misplaced, as that case involved a resolution issued by the Office of the President in the exercise of its quasi-judicial functions. In contrast, the OWWA Omnibus Policies constitute an administrative issuance. The Court further clarified that the petition before it, which raised a pure question of law regarding the RTC’s jurisdiction, was properly filed via a petition for review on certiorari under Rule 45 of the Rules of Court. The Supreme Court reversed and set aside the RTC Orders and remanded the case to the RTC for further proceedings.