Decision
6
G.R. No. 221139
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. 36 (Emphasis in the original,
citations omitted)
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.
It does not.
34
Id. at 329-330.
35
803 Phil. 36 (2017) [Per J. Leonen, En Banc].
36
Id. at 57.
J