• 13.8. Doctrine of Conclusive Finality of Administrative Decisions. – In Danagn vs.
National Labor Relations Commission (127 SCRA 706), the Supreme Court reiterated the principle long upheld by it that administrative findings of fact that are supported by substantial evidence must be treated by courts as final. This follows a trend in modern legislation kwon as the doctrine of conclusive finality, which is justified by the comity that courts extend to the executive branch and the recognition of the expertise of administrative agencies in dealing with particular questions of facts. Since Ang Tibay vs. Court of Industrial Relatives (69) Phil. 635), a classic ruling in Philippine jurisprudence, the Supreme Court has utilized a convenient rule of thumbs that defines substantial evidence as evidence that need not be overwhelming or preponderant, but what a reasonable mind will accept as adequate to support a conclusion. In looking for substantial evidence, a court will not weigh conflicting evidence or determine the credibility of witnesses, or substitute its judgment for that of administrative agency. As said in Loa Tang Bung vs. Fabre (81 Phil. 682), the Supreme Court will merely see whether adequate evidence sustains the administrative finding, and if it does, keep off the judicial band. It is perfectly consistent for a court to find substantial evidence even if it may find differently on the whole evidence presented. • Slide Title • 13.9. Administrative Appeal and Review.- The decision of the Board Dentistry shall, unless appealed to the Professional Regulation Commission (PRC), become final and executory after fifteen (15) days from receipt of notice of judgment or decision. • • The Court of Appeals shall exercise execlusive appellate jurisdiction over all final judgments, resolutions, orders or awards of Regional Trial Courts and quasi-judicial agencies, instrumentalities, boards or commission. • • Independently of statutory authority, the President, as the administrative head, and under his constitutional power of control of executive department, bureaus and offices, on his motion or on appeal of some individual who might deem himself aggrieved by the action of an administrative official, exercise his power of revision. • 13.10. Judicial Remedies.- The following are judicial remedies of parties to administrative decisions: • • 1. Certiorari – It is a special civil action directed against any tribunal, board or officer exercising judicial or quasi-judicial functions which or who has acted without or in excess of its or his jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction, and there is no appeal, or any plain, speedy, and adequate remedy in the ordinary course of law, whereby a person aggrieved thereby may file a verified petition in the proper court, alleging the facts with certainty and praying that judgment be rendered annulling or modifying the proceedings of such tribunal, board or officer, and granting such incidental reliefs as law and justice may require. • • 2. Prohibition – It is a special civil action directed against any tribunal, corporation, board officer or person, whether exercising judicial, quasi-judicial or ministerial functions, which or who has acted without or in excess of its or his jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction, and there is no appeal or any other plain, speedy, and adequate remedy in the ordinary course of law, whereby a person aggrieved thereby may file a verified petition in the proper court, alleging the facts with certainty and praying the judgment be rendered commanding the respondent to desist from further proceedings in the action or matter specified therein, or otherwise granting such incidental reliefs as law and justice may require • 3. mandamus – It is a special civil action directed against any tribunal, corporation, board, officer or person which or who unlawfully neglects the performance of an act which the law specifically enjoins as a duty resulting from an office, trust, or station, or unlawfully excludes another from the use and enjoyment of a right or office to which such other is entitled, and there is no other plain, speedy and adequate remedy in the ordinary course of law, whereby the person aggrieved thereby may file a verified petition in the proper court, alleging the facts with certainty and praying that judgment be rendered commanding the respondent, immediately or at some other time to be specified by the court, to do the act required to be done to protect the rights of the petitioner, and to pay the damages sustained by the petitioner by reason of the wrongful acts of the respondent. • • 4. Preliminary Injunction – It is an order granted at any stage of an action or proceeding prior to the judgment or final order, requiring a party or a court, agency or a person to refrain from a particular act or acts. • • 5. Preliminary Mandatory Injunction – It is an order granted at any stage of an action or proceeding prior to the judgment or final order, requiring a party or a court, agency or a person to perform a particular act or acts.