Definition of the Doctrine The doctrine of hierarchy of courts provides that although courts may have concurrent jurisdiction over a subject matter, concurrency does not grant a party the absolute freedom to file a petition in any court of their choice. The doctrine mandates a party to file a case first before the lowest court possible having the appropriate jurisdiction. This principle reflects the judicial hierarchy in the Philippines, which generally proceeds from Municipal Trial Courts (MTCs)/Metropolitan Trial Courts (MeTCs)/Municipal Circuit Trial Courts (MCTCs) to Regional Trial Courts (RTCs), then the Court of Appeals, and finally the Supreme Court.
Purpose of the Doctrine The hierarchy of courts serves as the general determinant of the appropriate forum for seeking relief. Adherence to the doctrine is necessary to prevent inordinate demands upon the higher courts' time and attention, which should be reserved for matters of national concern and those requiring their unique perspective. It ensures that cases are resolved by the court best equipped to handle them at the appropriate level, respecting the appellate structure.
Application to Concurrent Jurisdiction and Extraordinary Writs Courts may have concurrent original jurisdiction over certain actions, such as petitions for certiorari, prohibition, mandamus, and habeas corpus. However, the doctrine of hierarchy dictates the proper venue for initiating such actions. While the Supreme Court, Court of Appeals, and Regional Trial Courts may share concurrent original jurisdiction for these extraordinary writs, petitions should generally be filed first with the lowest court having the appropriate jurisdiction. For instance, petitions for certiorari, prohibition, and mandamus against lower courts and bodies should typically be filed with the Regional Trial Court, then the Court of Appeals, before resorting to the Supreme Court.
Exceptions to the Doctrine The doctrine of hierarchy of courts is not an absolute rule and allows for exceptions. Direct resort to the Supreme Court or a higher court is permitted only for special and compelling circumstances. These exceptional instances include:
- When there are special and important reasons clearly stated in the petition.
- When dictated by public welfare and the advancement of public policy.
- When demanded by the broader interest of justice.
- When the challenged orders are patent nullities.
- When there are analogous exceptional and compelling circumstances that justify immediate and direct handling by the higher court.
- When there are genuine issues of constitutionality that must be addressed immediately.
Other identified exceptions relate to specific scenarios, such as when there is no other plain, speedy, and adequate remedy, when strong public interest is involved, or in cases involving writs of quo warranto. Additionally, the rule may be disregarded when the matter involves grave abuse of discretion amounting to lack or excess of jurisdiction.
Relationship with Appellate Jurisdiction The hierarchy of courts is also fundamental to appellate jurisdiction. Decisions of lower courts are reviewed by higher courts in a specific order. For example, decisions of the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts in their territorial jurisdiction are appealable to the Regional Trial Courts. Decisions of the Regional Trial Courts may be appealable to the Court of Appeals. Decisions of quasi-judicial agencies may be appealable to the Court of Appeals or the Supreme Court depending on the nature of the case and the law. The Supreme Court is the final arbiter and reviews decisions from the Court of Appeals, Sandiganbayan, and Court of Tax Appeals, among others. A lower court cannot reverse or set aside the decisions or orders of a superior court.