Jessa Kasandra Ng

Doctrine of Primary Administrative Jurisdiction

The doctrine of primary jurisdiction holds that if a case is such that its
determination requires the expertise, specialized training and knowledge of
the proper administrative bodies, relief must first be obtained in an
administrative proceeding before a remedy is supplied by the courts even if
the matter may well be within their proper jurisdiction. It applies where a claim
is originally cognizable in the courts, and comes into play whenever
enforcement of the claim requires the resolution of issues which, under a
regulatory scheme, have been placed within the special competence of an
administrative agency. In such a case, the court in which the claim is sought
to be enforced may suspend the judicial process pending referral of such
issues to the administrative body for its view or, if the parties would not be
unfairly disadvantaged, dismiss the case without prejudice. The objective of
the doctrine of primary jurisdiction is to guide the court in determining
whether it should refrain from exercising its jurisdiction until after an
administrative agency has determined some question or some aspect of
some question arising in the proceeding before the court.

Euro-Med Laboratories Inc. vs. Province of Batangas

G.R. No. 148106, July 17, 2006

FACTS: A civil case for collection of sum of money by Euro-Med against the
Province of Batangas in the amount of ₱487,662.80 of IVF incurred by
respondent in behalf of various public hospitals. The same was not paid even
after demands were made.

At conclusion of petitioner’s presentation of evidence respondent filed

a motion to dismiss the complaint on the ground that the primary jurisdiction
over petitioner’s money claim is lodged with the COA.
 RTC dismissed petitioners complaint without prejudice to the filing of a
money claim with the COA.
.

ISSUE: Does the COA have primary jurisdiction over the case at hand?

RULING: Yes, the doctrine of primary jurisdiction holds that if a case is such
that its determination requires the expertise, specialized training and
knowledge of an administrative agency, relief must first be obtained in an
administrative proceeding before resort to the courts is done.

Case at bar is enforcement of money claims against the government,

which brought it under the COA’s domain under Sec. 26 of the Government
Auditing Code of the Philippines. Second, the claim was founded on a series
of purchases for medical supplies of respondent’s public hospitals, such
being agreed by both parties to be governed by the LGU on supply and
property management as stated in Sec. 383 of said code.

Petition denied. RTC orders affirmed.