G.R. No. L-18496; July 30, 1962
JOSE L. GONZALES, appellee, vs. SECRETARY OF EDUCATION, ET AL., appellants.

FACTS

Jose L. Gonzales was appointed Principal of Lambunao High School in 1954. Pursuant to Republic Act No. 1595 , this school was converted into the Iloilo Vocational High School, effective July 1, 1957. On February 18, 1959, Gonzales received a letter from the Secretary of Education appointing him to a different position as Head of the Related Subjects Department. On the same date, he learned that the Director of Public Schools had appointed Alfredo Pineda as Principal of the newly converted Iloilo Vocational School. Pineda attempted to assume the office, but Gonzales refused to yield.
Gonzales filed a written protest against these appointments on February 19, 1959, addressed to the Superintendent of the Iloilo School of Arts and Trades, who forwarded it to the Director of Public Schools on February 25, 1959. However, without waiting for any administrative action on his protest, Gonzales filed a petition for prohibition with preliminary injunction in the Court of First Instance of Iloilo on February 23, 1959. The lower court ruled in favor of Gonzales, declaring him the incumbent principal and restraining Pineda and the Director from implementing Pineda’s appointment.

ISSUE

Whether the Court of First Instance erred in taking cognizance of the case despite Gonzales’s failure to exhaust administrative remedies before seeking judicial relief.

RULING

The Supreme Court reversed the lower court’s decision and dismissed the case. The legal logic centers on the doctrine of exhaustion of administrative remedies. The Court held that Gonzales and Pineda were employees of the executive department, and the Department of Education was the agency called upon to implement Republic Act No. 1595 . If an aggrieved party believes an administrative action is erroneous, the established rule requires that they first avail themselves of the plain, speedy, and adequate remedy provided within the administrative department before seeking judicial intervention. This means the prescribed administrative procedures must not only be initiated but pursued to their appropriate conclusion.
The facts clearly show that Gonzales, while initiating the correct administrative procedure by filing a protest on February 19, 1959, filed his court action on February 23, 1959—even before his protest was formally forwarded to the Director of Public Schools on February 25. By doing so, he deprived his superior officers of the opportunity to review and potentially reconsider the contested appointments. The Court emphasized that this rule applies with greater force where, as in this case, there was no showing of undue pressure to force Gonzales from his position. Consequently, his judicial action was instituted prematurely and must be dismissed.