1. CONCEPT
Save for the single specific instance provided by the Constitution under Section 18, Article VII, cases the resolution of which depends on the determination of questions of fact cannot be brought directly before the [the Supreme Court] because we are not a trier of facts. [The Supreme Court is] not equipped, either by structure or rule, to receive and evaluate evidence in the first instance; these are the primary functions of the lower courts or regulatory agencies. This is the raison d’etre behind the doctrine of hierarchy of courts. It operates as a constitutional filtering mechanism designed to enable this Court to focus on the more fundamental tasks assigned to it by the Constitution. It is a bright-line rule which cannot be brushed aside by an invocation of the transcendental importance or constitutional dimension of the issue or cause raised. (In Re: Habeas Corpus of Inmates Reyes et al., G.R. No. 251954, 10 June 2020)
2. SUPREME COURT
| General Rule: Under the principle of hierarchy of courts, direct recourse to [the Supreme 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. (Dy v. Bibat-Palamos, G.R. No. 196200, 11 September 2013 |
| Exception: … 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. (Ibid.) |
a. Concurrence of original jurisdiction with Regional Trial Courts and Court of Appeals
While this Court has original and concurrent jurisdiction with the RTC and the CA in the issuance of writs of certiorari, prohibition, mandamus, quo warranto, and habeas corpus (extraordinary writs), direct recourse to this Court is proper only to seek resolution of questions of law. Save for the single specific instance provided by the Constitution under Section 18, Article VII, cases the resolution of which depends on the determination of questions of fact cannot be brought directly before the Court because we are not a trier of facts. We are not equipped, either by structure or rule, to receive and evaluate evidence in the first instance; these are the primary functions of the lower courts or regulatory agencies. This is the raison d’etre behind the doctrine of hierarchy of courts. It operates as a constitutional filtering mechanism designed to enable this Court to focus on the more fundamental tasks assigned to it by the Constitution. It is a bright-line rule which cannot be brushed aside by an invocation of the transcendental importance or constitutional dimension of the issue or cause raised.
b. Concurrence of original jurisdiction with Court of Appeals
Although the [Supreme Court] has concurrent jurisdiction with the Court of Appeals in issuing the writ of certiorari, direct resort is allowed only when there are special, extraordinary or compelling reasons that justify the same. The Court enforces the observance of the hierarchy of courts in order to free itself from unnecessary, frivolous and impertinent cases and thus afford time for it to deal with the more fundamental and more essential tasks that the Constitution has assigned to it. There being no special, important or compelling reason, the petitioner thereby violated the observance of the hierarchy of courts, warranting the dismissal of the petition for certiorari.(Saint Mary Crusade to Alleviate Poverty of Brethren Foundation, Inc. v. Riel, G.R. No. 176508, 12 January 2015)
