DOCTRINE OF JUDICIAL HIERARCHY, GENERAL RULE AND EXCEPTIONS

Courts have a hierarchical order. 

The first level courts are the Metropolitan Trial Courts, Municipal Trial Courts, Municipal Trial Courts in Cities, and the Municipal Circuit Trial Courts.

The second level courts are the Regional Trial Courts.

 Next, we have the Court of Tax Appeals, Sandiganbayan, and the Court of Appeals.

Finally, we have the Supreme Court.

Under the doctrine of judicial hierarchy, when a case falls within the concurrent jurisdiction of courts of different levels, the case must be filed with the court of the lowest level so that the higher level courts will not be unduly burdened.

There are four exceptions to this doctrine:

(1) when dictated by the public welfare and the advancement of public policy; 

(2) when demanded by the broader interest of justice; 

(3) when the challenged orders were patent nullities; or 

(4) when analogous exceptional and compelling circumstances called for and justified the immediate and direct handling of the case.

The Supreme Court explained the general rule and exception were explained in the case of ERNESTO DY VS. HON. GINA M. BIBAT-PALAMOS ET AL, G.R. No. 196200, September 11, 2013, as follows:

Petitioner argues that his situation calls for the direct invocation of this Court’s jurisdiction in the interest of justice. Moreover, as pointed out by the RTC, what is involved is a judgment of the Court which the lower courts cannot modify. Hence, petitioner deemed it proper to bring this case immediately to the attention of this Court. Lastly, petitioner claims that the present case involves a novel issue of law – that is, whether in an action to recover, a defendant in wrongful possession of the subject matter in litigation may be allowed to return the same in a deteriorated condition without any liability.

Respondent, on the other hand, contends that the petition should have been filed with the CA, following the doctrine of hierarchy of courts. It pointed out that petitioner failed to state any special or important reason or any exceptional and compelling circumstance which would warrant a direct recourse to this Court.

Under the principle of hierarchy of courts, direct recourse to this Court is improper because the Supreme Court is a court of last resort and must remain to be so in order for it to satisfactorily perform its constitutional functions, thereby allowing it to devote its time and attention to matters within its exclusive jurisdiction and preventing the overcrowding of its docket. 16 Nonetheless, the invocation of this Court’s original jurisdiction to issue writs of certiorari has been allowed in certain instances on the ground of special and important reasons clearly stated in the petition, such as,(1) when dictated by the public welfare and the advancement of public policy; (2) when demanded by the broader interest of justice; (3) when the challenged orders were patent nullities; or (4) when analogous exceptional and compelling circumstances called for and justified the immediate and direct handling of the case.

This case falls under one of the exceptions to the principle of hierarchy of courts. Justice demands that this Court take cognizance of this case to put an end to the controversy and resolve the matter which has been dragging on for more than twenty (20) years. Moreover, in light of the fact that what is involved is a final judgment promulgated by this Court, it is but proper for petitioner to call upon its original jurisdiction and seek final clarification.