GR L 15849; (June, 1961) (Digest)
G.R. No. L-15849. June 30, 1961. BERNARDO SEBASTIAN, petitioner-appellant, vs. JUAN N. GERARDO, in his capacity as Hearing Officer of Regional Office No. 3 of the Department of Labor and CRISPIN SELOSA, respondents-appellees.
FACTS
Respondent Crispin Selosa filed a complaint for overtime pay against petitioner Bernardo Sebastian before Regional Office No. 3 of the Department of Labor. The hearing officer, respondent Juan N. Gerardo, rendered a decision awarding Selosa the sum of P850.37. Sebastian did not appeal this decision to the Labor Standards Commission as required by the administrative rules. Instead, he filed a petition for certiorari with preliminary injunction in the Court of First Instance of Manila, seeking to nullify the regional office proceedings for lack of jurisdiction.
The lower court dismissed Sebastian’s petition. It ruled that Sebastian failed to exhaust administrative remedies by not appealing the regional office’s decision to the Labor Standards Commission, as mandated by Section 12, Article 3 of Republic Act No. 997 , as amended, and the implementing Reorganization Plan No. 20-A. Sebastian appealed this dismissal to the Supreme Court.
ISSUE
Whether the Court of First Instance correctly dismissed the petition for certiorari on the ground of failure to exhaust administrative remedies, despite the petitioner’s claim that the regional office lacked jurisdiction over the money claim.
RULING
The Supreme Court reversed the lower court’s decision. The legal logic proceeds from a fundamental principle: the doctrine of exhaustion of administrative remedies does not apply when the assailed agency lacks jurisdiction. The Court, citing a series of contemporaneous decisions, held that Section 25 of Reorganization Plan No. 20-A, which granted regional offices original and exclusive jurisdiction over money claims like overtime pay, was not authorized by its enabling law, Republic Act No. 997 . The legislature did not intend to empower the Reorganization Commission to divest regular courts of jurisdiction over such claims and vest it in administrative regional offices.
Consequently, Regional Office No. 3 acted without jurisdiction. Since jurisdiction is conferred only by law and cannot be bestowed by agreement or acquiescence, all proceedings before it, including its decision, were null and void. An action or decision rendered by a body without jurisdiction is a complete nullity. Therefore, Sebastian was not required to appeal the void decision to the Labor Standards Commission before seeking judicial relief. A party need not exhaust administrative remedies when the core challenge is to the very authority of the agency to act. The proper recourse was a direct judicial action to question the jurisdiction. The Supreme Court set aside the regional office’s proceedings and judgment.