G.R. No. L-14559; November 29, 1960
REYNALDO MADRIÑAN, ET AL., petitioners-appellees, vs. VICENTE G. SINCO, as President of the University of the Philippines, ET AL., respondents-appellants.

FACTS

Petitioners, students of the University of the Philippines, filed a petition for prohibition and mandamus with preliminary injunction in the Manila Court of First Instance. They assailed the validity of Administrative Circular No. 1, series 1958-1959, issued by University President Vicente G. Sinco, and a clarifying memorandum issued by the Chairman of the Committee on Student Organizations and Activities. The Circular aimed to broaden student participation in extracurricular activities and improve discipline by limiting representation, stating that not more than one member of any student organization could hold office in specified university student bodies like the Student Council or the Philippine Collegian staff for any particular term. Petitioners claimed to be adversely affected by these regulations. The trial court annulled the Circular and memorandum, declaring them unjust, unreasonable, undemocratic, oppressive, constituting class legislation, infringing on the constitutional right to freedom of association, and promulgated without legal authority. Respondents appealed, questioning the venue, the petitioners’ right to sue, and asserting the President’s power to issue the Circular. They also raised the procedural point that petitioners failed to exhaust available administrative remedies by not first appealing to the University’s Board of Regents.

ISSUE

Whether the petitioners were required to exhaust administrative remedies by appealing to the Board of Regents before resorting to judicial action to challenge the validity of Administrative Circular No. 1.

RULING

Yes. The Supreme Court reversed the decision of the trial court and dismissed the petition. The Court held that the petitioners failed to exhaust their administrative remedies. The government of the University of the Philippines is vested by law in the Board of Regents (Sec. 4, Act 1870), and the President administers the University only “in so far as authorized by said Board.” The ultimate authority resides with the Board of Regents, which has the power to annul or modify the President’s circular. Petitioners were legally obligated to appeal to the Board before seeking judicial review. This principle of exhaustion of administrative remedies is founded on practical considerations and comity between government departments, requiring courts to refrain from acting until administrative processes are complete. The Court found petitioners’ claim that they could not have resorted to the Board in time unpersuasive, noting they had several days to submit a protest before the scheduled student election and that the Board could have decided the matter even after the election. Since the petitioners bypassed the available administrative remedy, the special civil actions should not have been entertained by the trial court. Given this disposition, the Supreme Court deemed it unnecessary to address the other issues raised regarding the Circular’s validity.