**Facts:**
1. **Initial Complaint:** In POEA Case No. RV 07-03-0442, the POEA found that Principalia Management and Personnel Consultants, Inc. (Principalia) had collected an excessive placement fee from Alejandro Ramos. As this was a serious offense under Section 2(b), Rule I, Part VI of the 2002 POEA Rules and Regulations, Principalia’s recruitment license was canceled on June 8, 2009.
2. **Immediate Execution:** Under Section 5, Rule V, Part VI of the POEA Rules, the cancellation of Principalia’s license was immediately executory upon issuance of the order, despite the potential for appeal.
3. **RTC Action:** On June 26, 2009, Principalia filed for an injunction with the RTC of Mandaluyong City to stay the execution of the POEA’s order, citing deprivation of due process and potential irreparable harm to hundreds of overseas Filipino workers awaiting deployment. The RTC issued a 72-hour Temporary Restraining Order (TRO).
4. **Administrative Appeal:** Principalia appealed the POEA order to the Secretary of the Department of Labor and Employment (DOLE) on July 8, 2009.
5. **RTC Proceedings:** The POEA filed a Motion to Dismiss in the RTC on July 22, 2009, citing lack of jurisdiction, failure to exhaust administrative remedies, and forum shopping. The RTC denied the motion on July 28, 2009, holding jurisdiction over the injunction.
6. **RTC Reconsideration:** After the denial of its Motion to Dismiss, the POEA’s motion for reconsideration was likewise denied by the RTC on October 5, 2009.
7. **CA Involvement:** The POEA petitioned the Court of Appeals (CA) for Certiorari and Prohibition, challenging the RTC orders. On April 4, 2011, the CA held that the RTC had jurisdiction over the injunction. A subsequent Motion for Reconsideration by POEA was denied by the CA on August 31, 2011.
8. **Mootness Argument:** Principalia subsequently filed a motion to dismiss the injunction case on May 22, 2013, claiming mootness because its license had been renewed. The RTC granted the dismissal.
9. **Appeal to Supreme Court:** The POEA persisted, asserting that a legal resolution was needed to clarify jurisdictional boundaries between the RTC and the DOLE Secretary, despite the case ostensibly being moot.
**Issues:**
1. **Mootness of the Case:** Whether the case is moot due to the renewal of Principalia’s license.
2. **Jurisdiction of RTC over Injunction:** Whether the RTC had jurisdiction to entertain Principalia’s injunction to stay the immediate execution of the POEA’s cancellation order.
3. **Forum Shopping:** Whether Principalia committed forum shopping by filing the injunction with the RTC while appealing the cancellation to the DOLE.
4. **Exhaustion of Administrative Remedies:** Whether Principalia violated the principle of exhaustion of administrative remedies by filing directly with the RTC.
**Court’s Decision:**
1. **Mootness:** The Supreme Court recognized the case as moot since Principalia’s license was renewed, removing the need for injunctive relief. However, it proceeded to address the legal questions due to the case’s potential recurrence.
2. **Jurisdiction Over Injunction:** The Supreme Court affirmed the CA’s ruling that the RTC had jurisdiction over the injunction case. It noted that while administrative bodies like the POEA handle disciplinary actions, courts can grant injunctions to address issues like due process and immediate harms, especially where administrative remedies may be inadequate or delayed.
3. **Forum Shopping:** The Court determined that Principalia did not commit forum shopping because the reliefs sought before the RTC (injunction) and the DOLE (appeal on merits) were different. Consequently, there was no identity of parties or reliefs.
4. **Exhaustion of Administrative Remedies:** The Court concluded that the exhaustion of administrative remedies is not absolute and can be bypassed in cases of immediate harm or deprivation of due process. In this case, the RTC was right in allowing the injunction to proceed to trial.
**Doctrine:**
– **Mootness of Cases:** Courts must refrain from deciding moot cases unless the issue is capable of repetition yet evading review.
– **Jurisdiction over Injunctions:** RTCs have jurisdiction over civil actions for injunction, even against administrative orders, where due process issues or immediate irreparable damage are alleged.
– **Non-Exhaustion Exceptions:** Exceptions to the principle of exhaustion include cases alleging deprivation of due process, urgency, or where administrative remedies are inadequate to address immediate harm.
**Class Notes:**
– **Judicial Power and Mootness:** Sections on mootness stress judicial restraint unless exceptional circumstances justify a decision.
– **Jurisdiction and Injunctions:** Section 21, BP 129 and Section 19, BP 129, as amended by RA 7691, confer jurisdiction to RTCs for injunctions involving irreparable harm or due process claims.
– **Forum Shopping and Administrative Remedies:** Variance in relief sought and exceptions to administrative remedies principle if immediate judicial intervention is warranted.
**Historical Background:**
This case highlights the tension between administrative agencies’ quasi-judicial powers and judicial oversight, particularly in the context of labor migration and the protection of worker rights in the Philippines. The specifics of this case arose amid growing international labor arrangements and the regulatory frameworks governing recruitment agencies, emphasizing due process protections in administrative punitive actions.
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