DOCTRINE OF HIERARCHY OF COURTS AND EXCEPTIONS

The doctrine of hierarchy of courts is grounded on considerations of judicial economy. In Aala v. Mayor Uy:^[30]

The doctrine on hierarchy of courts is a practical judicial policy designed to restrain parties from directly resorting to this Court when relief may be obtained before the lower courts. The logic behind this policy is grounded on the need to prevent "inordinate demands upon the Court's time and attention which are better devoted to those matters within its exclusive jurisdiction," as well as to prevent the congestion of the Court's dockets. Hence, for this Court to be able to "satisfactorily perform the functions assigned to it by the fundamental charter[,]" it must remain as a "court of last resort." This can be achieved by relieving the Court of the "task of dealing with causes in the first instance."^[31] (Citations omitted)

Applying this doctrine is not merely for practicality; it also ensures that courts at varying levels act in accord with their respective competencies. The Diocese of Bacolod v. Commission on Elections^[32] noted that "[t]he doctrine that requires respect for the hierarchy of courts was created by this court to ensure that every level of the judiciary performs its designated roles in an effective and efficient manner."^[33] Thus:

Trial courts do not only determine the facts from the evaluation of the evidence presented before them. They are likewise competent to determine issues of law which may include the validity of an ordinance, statute, or even an executive issuance in relation to the Constitution. To effectively perform these functions, they are territorially organized into regions and then into branches. Their writs generally reach within those territorial boundaries. Necessarily, they mostly perform the all-important task of inferring the facts from the evidence as these are physically presented before them. In many instances, the facts occur within their territorial jurisdiction, which properly present the 'actual case' that makes ripe a determination of the constitutionality of such action. The consequences, of course, would be national in scope. There are, however, some cases where resort to courts at their level would not be practical considering their decisions could still be appealed before the higher courts, such as the Court of Appeals.

The Court of Appeals is primarily designed as an appellate court that reviews the determination of facts and law made by the trial courts. It is collegiate in nature. This nature ensures more standpoints in the review of the actions of the trial court. But the Court of Appeals also has original jurisdiction over most special civil actions. Unlike the trial courts, its writs can have a nationwide scope. It is competent to determine facts and, ideally, should act on constitutional issues that may not necessarily be novel unless there are factual questions to determine.

This court, on the other hand, leads the judiciary by breaking new ground or further reiterating — in the light of new circumstances or in the light of some confusions of bench or bar — existing precedents. Rather than a court of first instance or as a repetition of the actions of the Court of Appeals, this court promulgates these doctrinal devices in order that it truly performs that role.^[34] (Citation omitted)

The doctrine of hierarchy of courts admits of exceptions in Aala:^[35]

However, the doctrine on hierarchy of courts is not an inflexible rule. In Spouses Chua v. Ang, this Court held that "[a] strict application of this rule may be excused when the reason behind the rule is not present in a case[.]" This Court has recognized that a direct invocation of its original jurisdiction may be warranted in exceptional cases as when there are compelling reasons clearly set forth in the petition, or when what is raised is a pure question of law.

In a fairly recent case, we summarized other well-defined exceptions to the doctrine on hierarchy of courts. Immediate resort to this Court may be allowed when any of the following grounds are present:

• (1) when genuine issues of constitutionality are raised that must be addressed immediately;

•  

• (2) when the case involves transcendental importance;

•  

• (3) when the case is novel;

•  

• (4) when the constitutional issues raised are better decided by this Court; (5) when time is of the essence;

•  

• (6) when the subject of review involves acts of a constitutional organ;

•  

• (7) when there is no other plain, speedy, adequate remedy in the ordinary course of law;

•  

• (8) when the petition includes questions that may affect public welfare, public policy, or demanded by the broader interest of justice;

•  

• (9) when the order complained of was a patent nullity; and

•  

• (10) when the appeal was considered as an inappropriate remedy.

It does not escape this Court's attention that an equally effective avenue for relief was available to petitioner through recourse to the Court of Appeals. This Court, however, takes cognizance of the Petition, in the interest of addressing the novel issue of whether the Indigenous Peoples' Rights Act works to remove from courts of law jurisdiction over criminal cases involving indigenous peoples.