Scribd
Upload
156 views2 pages

34 - Regino Vs Pangasinan Colleges of Science and Technology

Khristine Rea Regino filed a complaint for damages against Pangasinan Colleges of Science and Technology (PCST) and two of its teachers. PCST filed a motion to dismiss arguing Regino failed to exhaust administrative remedies by not bringing the case to the Commission on Higher Education (CHED) first. The trial court agreed and dismissed the case. The Supreme Court ruled that the exhaustion of remedies doctrine did not apply because 1) Regino was seeking damages, which CHED does not have the power to award, 2) she was no longer a student at PCST so the issues could not be rectified administratively, and 3) the case involved issues of law and civil code interpretation

Uploaded by

Bibi Jumpol
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
156 views2 pages

34 - Regino Vs Pangasinan Colleges of Science and Technology

Khristine Rea Regino filed a complaint for damages against Pangasinan Colleges of Science and Technology (PCST) and two of its teachers. PCST filed a motion to dismiss arguing Regino failed to exhaust administrative remedies by not bringing the case to the Commission on Higher Education (CHED) first. The trial court agreed and dismissed the case. The Supreme Court ruled that the exhaustion of remedies doctrine did not apply because 1) Regino was seeking damages, which CHED does not have the power to award, 2) she was no longer a student at PCST so the issues could not be rectified administratively, and 3) the case involved issues of law and civil code interpretation

Uploaded by

Bibi Jumpol
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 2

Title Khristine Rea Regino vs Pangasinan Colleges of Science and Technology,

Gr. No. 156109


Ponente PANGANIBAN, J.
Doctrine Principle of Exhaustion of administrative remedies
Facts  Khristine Rea Regino was a 1st year computer science student at
Pangasinan Colleges of Science and Technology (PCST) and
enrolled for 2nd semester of S.Y 2001-2002
 PCST held a fund raising campaign “Rave Party and Dance
Revolution”, its proceeds were to go to the construction of the
school’s tennis and volleyball courts.
 Each student was required to pay for 2 tickets at P100 each
 The project was implemented by recompensing students who
purchased tickets with additional points in their test scores and
those who refused to pay were denied the opportunity to take
final exams.
 Regino refused to pay for the tickets because she was financially
strapped and prohibited by her religion from attending dance
parties.
 With this, Regino’s teachers disallowed her from taking the tests
for logic and statistics.
Contentions Petitioner [Regino] Respondent [PCST]
Filed a complaint for damages Filed motion to dismiss on the
against PCST and her 2 teachers ground of Regino’s failure to
(Gamurot & Baladad) before RTC exhaust administrative remedies.
The case should have been
initiated before CHED, not before
RTC
Lower Courts Granted PCST’s motion to dismiss. CHED not the courts, had jurisdiction
over the controversy. Dismissed the complaint for lack of cause of action
Appellate Court N/A
Issue W/N the principle of exhaustion of administrative remedies applies in a
civil action exclusively for damages based on violation of the human
relation provisions of the Civil Code, filed by a student against her
former school?
SC Ruling No. SC favored Regino’s contention that the doctrine finds no relevance
to the present case since she is praying for damages, a remedy beyond
CHED’s domain and well within the jurisdiction of the courts.

First, the doctrine of exhaustion of administrative remedies has no


bearing on the present case. In Factoran Jr. v. CA,12 the Court had
occasion to elucidate on the rationale behind this doctrine:

"The doctrine of exhaustion of administrative remedies is basic. Courts,


for reasons of law, comity, and convenience, should not entertain suits
unless the available administrative remedies have first been resorted to
and the proper authorities have been given the appropriate opportunity
to act and correct their alleged errors, if any, committed in the
administrative forum. x x x. "
Regino is not asking for the reversal of the policies of PCST. Neither is
she demanding it to allow her to take her final examinations; she was
already enrolled in another educational institution. A reversal of the acts
complained of would not adequately redress her grievances; under the
circumstances, the consequences of PCST’s acts could no longer be
undone or rectified.

Second, exhaustion of administrative remedies is applicable when there


is competence on the part of the administrative body to act upon the
matter complained of.

Administrative agencies are not courts; they are neither part of the
judicial system, nor are they deemed judicial tribunals. Specifically, the
CHED does not have the power to award damages. Hence, petitioner
could not have commenced her case before the Commission.

Third, the exhaustion doctrine admits of exceptions, one of which arises


when the issue is purely legal and well within the jurisdiction of the trial
court. Regino's action for damages inevitably calls for the application and
the interpretation of the Civil Code, a function that falls within the
jurisdiction of the courts.

In sum, SC held that the Complaint alleges sufficient causes of action


against PCST, and that it should not have been summarily dismissed.

You might also like