G.R. No. 223844 . June 28, 2017.
DANILO CALIVO CARIAGA, Petitioner, vs. EMMANUEL D. SAPIGAO and GINALYN C. ACOSTA, Respondents.

FACTS

Petitioner Danilo Calivo Cariaga filed a criminal complaint for Falsification of Public Documents, False Certification, and Slander by Deed against respondents, the Barangay Chairman and Secretary. Cariaga alleged that respondents made two false entries in the barangay blotter. One entry reported an unnamed resident hearing gunfire from Cariaga’s compound, and another stated that Cariaga and companions visibly carried firearms during a funeral march. These blotter entries were used by police to obtain a warrant for a search of Cariaga’s residence, which yielded a firearm and ammunition, leading to a criminal case against him that was later dismissed.
The Office of the Provincial Prosecutor (OPP) dismissed the complaint for lack of probable cause, finding the entries were made in good faith in the performance of official duties and based on personal knowledge. Cariaga’s motion for reconsideration was denied. He then elevated the matter to the Office of the Regional State Prosecutor (ORSP), which affirmed the OPP’s dismissal. Cariaga subsequently filed a petition for review directly with the Court of Appeals.

ISSUE

Whether the Court of Appeals correctly dismissed Cariaga’s petition for review on the ground of non-exhaustion of administrative remedies.

RULING

Yes, the Court of Appeals correctly dismissed the petition. The Supreme Court affirmed that the principle of exhaustion of administrative remedies mandates that a party must first avail of all administrative processes within an agency before seeking judicial intervention. The hierarchy within the National Prosecution Service (NPS) allows an appeal from an unfavorable Regional State Prosecutor (RSP) resolution to the Secretary of Justice (SOJ) before resorting to the courts. This procedure is established under Department Circular No. 70, as amended by Circular No. 70-A.
Cariaga’s direct recourse to the Court of Appeals after receiving an adverse ruling from the ORSP, without first appealing to the SOJ, constituted a fatal procedural defect. The rule on exhaustion of administrative remedies is not a mere technicality but a cornerstone of judicial procedure, ensuring that administrative agencies, which possess specialized competence, are given the opportunity to correct their own errors. Judicial review is premature until this process is completed. Consequently, the CA’s dismissal of the petition for review was proper, and the Supreme Court denied Cariaga’s petition.