Quasi-Judicial Function and Agencies: A Comprehensive Analysis
Introduction: Defining Quasi-Judicial Function
In the realm of governance, the functions of the executive, legislative, and judicial branches are traditionally distinct. However, in many legal systems, a nuanced role known as quasi-judicial function emerges, blurring the lines between these branches. Quasi-judicial functions refer to activities undertaken by administrative bodies that are akin to judicial functions, involving the adjudication of disputes, interpretation of laws, and decision-making with legal implications. This essay endeavors to delve deep into the concept of quasi-judicial functions and the agencies that wield them, exploring their significance, challenges, and implications within modern governance frameworks.
Understanding Quasi-Judicial Function
The term "quasi" denotes a resemblance or similarity, indicating that quasi-judicial functions share similarities with judicial functions but are not wholly judicial in nature. These functions typically involve the application of legal principles to specific cases, similar to how courts interpret laws and adjudicate disputes. However, unlike courts, quasi-judicial bodies operate within administrative frameworks, possessing specialized expertise in particular areas of law or policy. They are often tasked with making decisions on regulatory matters, licensing, disciplinary actions, and other administrative issues.
Characteristics of Quasi-Judicial Functions
Several key characteristics distinguish quasi-judicial functions from purely administrative or legislative functions:
Adjudicatory Powers: Quasi-judicial bodies have the authority to adjudicate disputes and make binding decisions that affect the rights and interests of individuals or organizations.
Application of Law: Like courts, quasi-judicial agencies interpret and apply legal principles, statutes, regulations, and precedents to resolve cases brought before them.
Impartiality and Fairness: These bodies are expected to act impartially and fairly, providing all parties with an opportunity to present their arguments and evidence before rendering a decision.
Due Process: Quasi-judicial proceedings often adhere to principles of due process, including the right to be heard, the right to legal representation, and the right to appeal decisions.
Limited Scope: While quasi-judicial bodies exercise judicial-like functions, their jurisdiction is typically limited to specific areas of law or policy, such as labor relations, environmental regulation, or professional licensing.
Examples of Quasi-Judicial Functions
Quasi-judicial functions manifest in various forms across different jurisdictions and regulatory domains:
Zoning Boards: These bodies determine land-use applications, such as requests for variances or special permits, by applying zoning ordinances and considering factors like community impact and property rights.
Administrative Tribunals: Tribunals specializing in
2. A 'quasi-judicial function' is a term which
applies to the action, discretion, etc., of public
administrative officers or bodies, who are
required to investigate facts, or ascertain the
existence of facts, hold hearings, and draw
conclusions from them, as a basis for their
official action and to exercise discretion of a
judicial nature.
DEFINITION
3. JUDICIAL QUASI-JUDICIAL
Judiciary Branch Executive Branch
Supreme Court, Higher Court, District
Court etc.
Arbitration panel or Tribunal Board
Subject to appeal in a higher court
Subject to appeal within the administrative bodies
or to a higher court
Legal decisions made by a court of law
Legal decisions made by administrative bodies or
boards
Decisions are made by a judge or a panel
of judges
Decisions are made by individuals or panels
appointed by the agency
Based on the application of existing laws
to a specific case
Based on the application of laws and regulations to
a specific case
4. (A) Jurisdiction must be properly acquired by
the administrative body.
(B) Due process must be observed in the
conduct of the proceedings.
5. Jurisdiction may be simply defined as the competence of an office or
body to act on a given matter or decide a certain question. Without
jurisdiction, the determinations made by the administrative bodies are
absolutely null and without any legal effect whatsoever. Such acts are
subject to direct and even collateral attack and may be assailed at any
time since they are regarded as invalid ab initio.
DEFINITION
6. Due process refers to the fundamental principle that individuals are
entitled to fair treatment, procedural fairness, and legal protection when
their rights, interests, or liberties are at stake in administrative
proceedings. This includes the right to notice of the charges or
allegations, the opportunity to be heard, the right to present evidence and
arguments, the right to cross-examine witnesses, and the right to a
reasoned decision based on the evidence presented. Due process ensures
that administrative actions or decisions are made impartially,
transparently, and in accordance with principles of justice and fairness.
DEFINITION
7. Are entities that possess powers and functions that are similar to
those of a court, but they are NOT considered full judicial bodies.
These bodies are typically established by governments to perform
SPECIFIC adjudicatory functions, often in specialized areas of law
or regulation. In administrative law, quasi-judicial bodies play a
crucial role in resolving disputes and making decisions in areas
such as administrative hearings, regulatory compliance, and
enforcement.
DEFINITION
8. • Administrative tribunals
• Commissions
• Boards
• Appeal Boards or Review Panels
• Adjudicative Officers or Hearing Officers
9. These are specialized bodies established to adjudicate
disputes in specific areas of administrative law. For
example, there may be tribunals dealing with labor
disputes, immigration appeals, or environmental
regulation.
10. Are bodies that are empowered to regulate and
adjudicate matters within their designated areas of
authority. They may have quasi-judicial powers to
conduct hearings, gather evidence, and make decisions
on issues such as consumer protection,
telecommunications, or securities regulation.
11. Similar to commissions, boards are entities with quasi-
judicial powers that oversee and regulate certain
industries or activities. Examples include licensing
boards for professionals like doctors or lawyers, as
well as zoning boards responsible for land-use
decisions.
12. These bodies hear appeals from decisions made by
lower-level administrative officials or agencies.
They review the decisions based on the record of the
proceedings and may have the authority to uphold,
overturn, or modify the original decision.
13. Some administrative agencies designate individual
officers to conduct hearings and make decisions in
contested cases. These officers act in a quasi-judicial
capacity, hearing evidence, making findings of fact,
and issuing decisions or recommendations.
14. Energy Regulatory
Commission (ERC)
02
03 04
05 06
Commission on Human
Rights (CHR)
Civil Service Commission
(CSC)
Land Transportation
Franchising and Regulatory
Board (LTFRB)
Professional Regulation
Commission (PRC)
Securities and Exchange
Commission (SEC)
Commission on Higher
Education (CHED)
National Police Commission
(NAPOLCOM)
07 08
01
15. Parties must be provided with adequate notice of the
proceedings, including the nature of the allegations or
issues involved, the time, date, and place of the hearing,
and any other relevant information. This allows parties to
prepare their defense and participate effectively in the
proceedings.
1. Notice
16. Parties have the right to be heard and present their case
before the quasi-judicial body. This includes the
opportunity to present evidence, cross-examine witnesses,
and make arguments in support of their position. The quasi-
judicial body must provide a reasonable opportunity for
parties to present their case and respond to allegations or
evidence presented by other parties.
2. Opportunity to be heard
17. Quasi-judicial proceedings must be presided over by
impartial decision-makers who have no personal or
financial interest in the outcome of the case. Decision-
makers must act objectively and independently, without
bias or favoritism toward any party involved in the
proceedings.
3. Impartial decision-maker
18. Quasi-judicial decisions must be based on the evidence
presented during the proceedings and relevant laws,
regulations, or policies. Decision-makers must carefully
evaluate the evidence, weigh the arguments presented by
the parties, and apply the law impartially in reaching their
decision.
4. Evidence-based decision-making
19. Parties have the right to appeal the decision of the quasi-
judicial body to higher authorities or judicial courts if they
believe that due process was not properly observed, or if
there are errors in the decision-making process. The right to
appeal provides a mechanism for parties to seek review of
the decision and ensure that their legal rights have been
protected.
5. Right to appeal
20. 1. Rules of Power
2. The Subpoena Power
3. The Contempt Power
21. This refers to the authority of quasi-judicial bodies to establish and
enforce rules of procedure governing their proceedings. These
rules outline the process by which cases are heard, including
procedures for filing complaints, presenting evidence, conducting
hearings, and issuing decisions. Rules of power ensure
consistency, fairness, and efficiency in quasi-judicial proceedings
by providing a clear framework for parties to follow.
1.Rules of Power
22. Quasi-judicial bodies have the authority to issue subpoenas,
compelling the attendance of witnesses or the production of
evidence relevant to the proceedings. This power enables quasi-
judicial bodies to gather information necessary for making
informed decisions and resolving disputes effectively. Subpoenas
may be issued to individuals, organizations, or entities requiring
their presence at hearings or the submission of documents or other
materials.
2. The Subpoena Power
23. The power to issue subpoena ad testificandum and
subpoena duces tecum is NOT inherent in administrative
body and may ONLY BE EXERCISED IF ALLOWED
by law and only in connection with the matter they are
authorized to investigate.
Note:
24. Quasi-judicial bodies possess contempt power, which allows them to
enforce compliance with their orders, directives, or rulings and
maintain the integrity of their proceedings. If a party fails to comply
with a subpoena, disobeys a lawful order, or engages in behavior that
disrupts the proceedings, the quasi-judicial body may hold them in
contempt. Contempt powers enable quasi-judicial bodies to impose
sanctions or penalties, such as fines or imprisonment, to compel
compliance and uphold the authority of the body.
3. The Contempt Power
25. Contempt Power is essentially a judicial power and
NOT inherent in administrative bodies. It MUST BE
EXPRESSLY GRANTED and must be used only in the
exercise of the quasi-judicial function.
Note:
26. It refers to the evaluation criteria or standards used to assess
the performance, competence, or legality of administrative
actions or decisions taken by government agencies or
administrative bodies. This test involves examining whether
the administrative action or decision is within the agency's
jurisdiction, supported by substantial evidence, consistent with
applicable laws and regulations, and free from error, bias, or
arbitrariness.
DEFINITION
27. The test of administrative function
assesses whether a particular action or
decision falls within the realm of
administrative authority, as opposed to
judicial or legislative functions. It
evaluates whether the action is
administrative in nature, involving the
implementation, execution, or application
of policies, rules, or regulations, rather
than the interpretation or adjudication of
legal disputes.
Quasi-judicial functions refer to the
adjudicatory or decision-making
powers exercised by administrative bodies
or agencies in resolving disputes,
interpreting laws or regulations, and
issuing orders or rulings that affect the
legal rights, duties, or interests of
individuals or entities. Quasi-judicial
bodies act in a manner similar to courts
but are distinct from judicial bodies in
their structure, procedures, and scope of
authority.
28. The facts of the case are as follows:
On January 13, 2009, respondent Juraldine N. Gerasraio (Juraldine) filed a complaint for illegal dismissal,
reinstatement, backwages, separation pay, declaration of the quitclaim and release as null and void,
13th month pay, litigation expenses, damages and attorney's fees, against petitioner Italkarat 18, Inc.
(Company).
Juraldine alleged that the Company hired him on June 1, 1990. In 1993, he was designated as the
Maintenance Head and Tool and Die Maker until his dismissal on November 20, 2008 on the ground of
serious business losses. He claimed that during and prior to the last quarter of 2008, the Company had
repeatedly informed its employees of its proposed retrenchment program because it was suffering from
serious business losses. In particular, Juraldine claimed that Noel San Pedro (San Pedro), the then Officer-
In-Charge (OIC)/Manager of the Company, informed him sometime in November 2008 that the Company
was planning to retrench a substantial number of workers in the Maintenance and Tool and Die Section; and
that if he opts to retire early, he will be given a sum of P170,000.00. San Pedro then allegedly cautioned
Juraldine that if he will not accept the offer to retire early, the Company would eventually retrench or
terminate him from his employment, in which case, he might not even receive anything.
National Labor Relations Commission (NLRC):
29. In light of the foregoing, Juraldine executed and signed a resignation letter and quitclaim on November 20, 2008. He
was then informed to return on November 25, 2008 to get his check worth P170,00.00. However, to his dismay,
Juraldine was later informed by San Pedro that he would be receiving only the amount of P26,901.34. Thus, Juraldine,
through his lawyer, sent a letter dated November 25, 2008, essentially demanding the amount of P170,000.00 he was
allegedly promised earlier. Since the Company did not respond, Juraldine filed the instant complaint for illegal
dismissal.
On the other hand, the Company essentially alleged that Juraldine voluntarily resigned from his job, thus, his claims are
baseless. The Company admitted that it hired Juraldine as maintenance personnel on December 1, 1989. It further
alleged that during the last year of his employment, Juraldine took leaves of absence in order to process his papers for a
possible seaman's job.
Moreover, the Company stated that on October 20, 2008, Juraldine tendered his resignation and demanded from the
Company the payment of his separation pay on account of his long years of service. On November 6, 2008 and on
November 20, 2008 respectively, he executed and signed a waiver and quitclaim which shows, inter alia, the
computation of his receivables. He then signed the voucher for this purpose and thereafter received the check issued to
him representing his last pay. Surprisingly, he sends a demand letter, through his lawyer, on November 28, 2008, for the
payment of P170,000.00 in addition to the amount already received by him. The Company refused to pay him the
additional amount for lack of basis in law and in fact.
National Labor Relations Commission (NLRC):
30. On April 3, 2009, the Labor Arbiter (LA) rendered a Decision declaring the complainant to have been
unlawfully dismissed. The dispositive portion thereof reads as follows:
WHEREFORE, foregoing considered, judgment is hereby rendered DECLARING the complainant to have
been unlawfully dismissed from his job in violation of his right to mandatory statutory due process, coupled
with bad faith and malice aforethought to humiliate his lowly status in the society. Thus, the respondents are
hereby ordered jointly and severally to reinstate the complainant to his previous work or its equivalent
immediately from notice hereof under Article 223 in [relation] to Article 279 of the Labor Code, and to pay
him of his partial back wages from December 2008 to the present in the amount of PHP53,456.00 at
PHP13,364.00 per month; moral damages in the amount of PHP100,000.00; and exemplary damages in the
amount of PHP50,000.00 each plus ten percent (10%) attorney's fees. Further, the respondents are hereby
ordered jointly and severally to deposit the said amounts to the Cashier of this Arbitration Branch within ten
(10) days from receipt hereof.
SO ORDERED.
The LA ruled that Juraldine was only forced to resign because of San Pedro's misrepresentation that he
would be paid P170,000.00 as separation pay. The LA likewise noted that in his quitclaim, Juraldine still
asserted his entitlement to the payment of whatever benefits that may be due him. In fine, the LA ruled that
Juraldine was illegally dismissed.
Ruling of the Labor Arbiter:
31. The Company appealed the Decision to the NLRC. Juraldine also inteiposed a partial appeal
to the NLRC, questioning the non-inclusion of his separation pay in the LA Decision. On
August 28, 2009, the NLRC granted the appeal of the Company, set aside and effectively
reversed the LA's Decision dated April 3, 2009. Juraldine filed a motion for reconsideration
but the same was denied by the NLRC in a Resolution dated October 30, 2009.
The NLRC found that Juraldine voluntarily resigned from his job. It also noted that San Pedro
could not have persuaded Juraldine to resign since the resignation happened on October 20,
2008 while the alleged promise of San Pedro was made on November 20, 2008, or one month
after. Also, the NLRC found that Juraldine's quitclaim was valid and executed for a reasonable
consideration.
The dispositive portion of the NLRC Decision reads as follows:
WHEREFORE, the challenged decision is SET ASIDE and a new one entered
DISMISSING the complaint for lack of merit.
SO ORDERED.
Ruling of the National Labor Relations Commission (NLRC):
32. Aggrieved, Juraldine filed a Petition for Certiorari with
the Court of Appeals. In a Decision dated February 22,
2012, the CA granted the Petition for Certiorari and
found that the NLRC committed grave abuse of
discretion. Thus, the CA reversed the NLRC Decision
and reinstated the LA's Decision dated April 3, 2009.
https://lawphil.net/judjuris/juri2020/sep2020/gr_221411_2020.html
33. SABERON, FLOR G.
MUÑEZ, KIM
FAJARDO, JHONNA C.
NIBRES, LIEZEL L.
RAPERA, REY ANTHONY
REGULAR, MONIQUE JESSICA
34. References:
Philippine Administrative Law
Book by Carlo L. Cruz
https://lawphil.net/judjuris/juri2020/sep2020/gr_221411_2020.html
https://administrativelaw.uslegal.com/administrative-agencies/quasi-judicial-functions/
https://www.tutorialspoint.com/judicial-and-quasi-judicial-acts
Official Websites of Quasi-Judicial Bodies:
- National Police Commission (NAPOLCOM): https://www.napolcom.gov.ph/
- Commission on Higher Education (CHED): https://ched.gov.ph/
- Energy Regulatory Commission (ERC): https://www.erc.gov.ph/
- Civil Service Commission (CSC): https://www.csc.gov.ph/
- Securities and Exchange Commission (SEC): https://www.sec.gov.ph/
- Land Transportation Franchising and Regulatory Board (LTFRB): https://ltfrb.gov.ph/
- National Labor Relations Commission (NLRC): https://www.nlrc.dole.gov.ph/
Legal Databases and Government Portals:
- Official Gazette of the Philippines: https://www.officialgazette.gov.ph/
- Supreme Court of the Philippines: https://sc.judiciary.gov.ph/
- LawPhil Project: https://lawphil.net/
- Chan Robles Virtual Law Library: https://www.chanrobles.com/