I. Overview and Philippine Framing

Administrative law in the Philippines is the body of law that governs:

the organization of administrative agencies,
the powers they exercise (rule-making, adjudication, enforcement, licensing, investigation),
the procedures they must follow, and
the judicial and internal controls that keep the administrative state consistent with the Constitution, statutes, and due process.

It sits at the intersection of constitutional law (delegation, separation of powers, due process, equal protection) and public administration (how government actually implements policy through departments, bureaus, commissions, and government-owned or controlled corporations).

In Philippine practice, talking about “classifications of administrative law” usually means classifying it along multiple, overlapping axes:

by source of the rule,
by subject/coverage,
by function (rule-making, adjudication, enforcement),
by type of administrative action (regulation, order, license, sanction),
by type of agency (department, constitutional commission, GOCC, LGU regulatory bodies),
by procedure and review (notice and hearing, quasi-judicial process, appeal, certiorari),
by effect (legislative vs interpretative rules, final vs interlocutory acts).

Because the administrative state is broad, no single classification captures everything. A useful legal article in Philippine context treats classifications as tools: each classification has consequences for validity, procedure, enforceability, and remedies.

II. Classifications by Source of Administrative Law

A. Constitutional Administrative Law

This is administrative law grounded directly on the 1987 Constitution, including:

Constitutional commissions and their powers (Civil Service Commission, Commission on Elections, Commission on Audit);
due process and equal protection limits on administrative action;
the non-delegation principle and permissible delegation of legislative power (with sufficient standards);
judicial power and expanded judicial review (including review for grave abuse of discretion).

Practical consequence: When an agency power is constitutionally rooted, it generally enjoys stronger footing, but it is also tightly bound by constitutional guarantees and structural limits.

B. Statutory Administrative Law

This is administrative law created by Congress through:

enabling laws creating agencies;
charters of commissions/authorities;
substantive statutes enforced by agencies (labor, environment, trade, banking, telecoms, energy, transportation, land use, etc.);
procedural statutes (e.g., those governing appeals, review, or agency procedure in special fields).

Practical consequence: The scope of an agency’s authority is primarily measured against its enabling statute. Ultra vires acts (beyond statutory power) are void.

C. Administrative/Regulatory Administrative Law (Agency Issuances)

This consists of rules, regulations, circulars, memoranda, orders, and guidelines issued by agencies under delegated authority.

Practical consequence: Validity depends on:

existence of delegated authority,
compliance with procedural requirements (where applicable),
consistency with the Constitution and statutes,
reasonableness and non-arbitrariness.

D. Jurisprudential Administrative Law

This is administrative law developed through Supreme Court and appellate decisions:

doctrines on exhaustion of administrative remedies,
primary jurisdiction,
finality of administrative decisions,
standards of judicial review (substantial evidence, arbitrariness, grave abuse),
due process in administrative settings,
doctrine of operative fact, etc.

Practical consequence: Even where statutes are silent, courts supply controlling standards (e.g., what counts as substantial evidence; when exceptions to exhaustion apply).

E. Local and Special-Field Administrative Law

In Philippine reality, administrative law also arises from:

local government regulatory powers (ordinances, permits, business licensing, zoning);
special regimes (tax, customs, immigration, land registration, procurement, utilities regulation).

Practical consequence: The classification matters because some areas carry special procedural tracks and remedies, and courts often respect specialized competence.

III. Classifications by Subject Matter or Coverage

A. General Administrative Law

Rules and doctrines that apply broadly across agencies:

delegation standards,
rule-making vs adjudication,
due process,
notice and hearing requirements,
publication/filing requirements for rules of general application,
judicial review principles.

B. Special Administrative Law

Regimes specific to a sector, where enabling statutes and agency practice dominate:

labor and employment relations,
banking and finance supervision,
energy regulation,
telecommunications,
environmental regulation,
public utilities, transportation,
land use and housing,
customs, immigration, taxation,
public procurement and government contracts.

Practical consequence: In special administrative law, the enabling statute often supplies unique standards (e.g., timelines, appeal routes, specialized remedies) and courts defer to the agency’s expertise—within lawful bounds.

IV. Classifications by Governmental Function

Philippine administrative law commonly classifies agency activity by whether it is quasi-legislative, quasi-judicial, or executive/administrative.

A. Quasi-Legislative (Rule-Making) Function

Agencies issue rules and regulations to implement statutes. This includes:

legislative rules (fill in details of a statute; bind the public like law);
supplementary regulations (specify technical standards, procedures, forms);
rate-setting, classification, and standard-setting by regulatory bodies.

Key Philippine idea: Rule-making is valid when Congress provides sufficient standards and the agency stays within that framework.

Procedural consequences:

Rules of general application typically require publication and, in many settings, filing requirements.
When rule-making affects rights broadly, good governance and due process values push toward consultation, transparency, and clear effectivity rules.

B. Quasi-Judicial (Adjudicatory) Function

Agencies decide controversies and determine rights/obligations through hearings and evidence, issuing:

orders, decisions, awards, resolutions.

Key Philippine idea: Quasi-judicial power must be granted by law (express or clearly implied), and agencies must observe administrative due process.

Procedural consequences:

Parties are entitled to notice and opportunity to be heard.
Decisions must be supported by substantial evidence (not necessarily proof beyond reasonable doubt).
There are typical internal remedies (motion for reconsideration, appeal to a higher administrative authority where provided) before judicial review.

C. Executive/Administrative (Enforcement and Management) Function

This includes:

investigation, inspection, monitoring, compliance audits;
licensing, permitting, registration;
enforcement actions (cease-and-desist, closure orders, recall, seizure in proper cases);
internal management and personnel actions (discipline, appointments, service rules).

Key Philippine idea: Many actions here are discretionary, but discretion is not license; it remains bounded by law, reasonableness, and non-arbitrariness.

V. Classifications by Type of Administrative Action

A. Rule (Regulation) vs Order

A rule is generally prospective and general in application (norm-setting).
An order is typically specific and often case-focused (directing a party or deciding a dispute).

Why it matters: Different procedural requirements often attach—especially in publication, hearing, and the route/timing of review.

B. Legislative Rules vs Interpretative Rules vs Internal Guidelines

Legislative rules: issued under delegated authority; create binding obligations or rights; usually require strict compliance with effectivity requirements.
Interpretative rules: explain what the agency thinks a statute or rule means; persuasive but not meant to add new burdens beyond the law.
Internal/organizational guidelines: intended primarily for agency staff operations; generally do not bind the public unless they effectively operate as legislative rules.

Why it matters: If an issuance functions like a legislative rule (creates new duties, imposes sanctions, changes legal relations), courts are more likely to require full compliance with publication/effectivity and substantive reasonableness.

C. Licensing/Permitting Acts

Acts granting permission to engage in activities otherwise regulated:

issuance, renewal, suspension, revocation of licenses;
imposition of conditions.

Why it matters: Licensing often triggers due process protections, especially in suspension/revocation, because it affects livelihood and property interests.

D. Investigatory vs Adjudicatory Acts

Investigatory: fact-finding, surveillance, inspection; may be preliminary.
Adjudicatory: determination of liability, rights, or sanctions.

Why it matters: The level of process due differs. Investigations can be more flexible, but when an investigation becomes the basis for sanctions, adjudicatory safeguards become essential.

E. Ministerial vs Discretionary Acts

Ministerial: the law dictates the result upon given facts (little to no judgment).
Discretionary: the agency chooses among lawful options based on policy/technical judgment.

Why it matters: Remedies differ. Courts are more reluctant to interfere with discretion, but will act when discretion is exercised with grave abuse, arbitrariness, or in violation of law.

F. Final vs Interlocutory (Non-Final) Agency Actions

Final: concludes the agency’s decision-making on the matter (subject to appeal/MR where provided).
Interlocutory: preliminary steps (show cause orders, subpoenas, interim directives).

Why it matters: Courts generally prefer review of final actions (to avoid premature interference), subject to exceptions (e.g., grave abuse, irreparable injury, lack of jurisdiction).

VI. Classifications by Nature of Power Exercised

A. Police Power Delegations

Many agencies regulate under delegated police power—health, safety, morals, general welfare—through:

standards, prohibitions, compliance regimes, sanctions.

Why it matters: Police power is broad but must be exercised reasonably; measures must have a lawful purpose and rational connection to that purpose.

B. Power of Eminent Domain (in Certain Agencies)

Some agencies or GOCCs have delegated power to expropriate, subject to constitutional limits and statutory requirements.

Why it matters: Expropriation is heavily judicialized; administrative steps may precede, but taking must comply with constitutional safeguards.

C. Taxing/Revenue-Related Powers

Revenue agencies may issue regulations, assessments, enforcement measures.

Why it matters: Tax matters often carry specialized appeal bodies and strict procedural rules.

D. Proprietary/Corporate Powers (GOCCs)

When the government acts as market participant through GOCCs, administrative law still applies, but some disputes may also look like private law.

Why it matters: The classification affects whether actions are treated as governmental regulation (public law) or corporate/proprietary acts (sometimes more private-law flavored), though still constrained by public accountability.

VII. Classifications by Institutional Type of Agency

A. Executive Departments and Bureaus

Classic agencies under the President’s control (subject to the President’s constitutional power of control).

Implication: Department Secretaries often act as alter egos of the President within lawful bounds.

B. Independent/Regulatory Commissions and Authorities

Bodies designed for expertise and continuity, sometimes with features of independence.

Implication: Courts often accord deference to technical expertise, but independence does not immunize from judicial review.

C. Constitutional Commissions

Bodies with constitutional stature and defined independence.

Implication: Their powers and limits are textually anchored; review focuses on constitutional design and compliance with due process.

D. Local Government Regulatory Bodies

LGUs exercise regulatory authority through ordinances and licensing.

Implication: Validity hinges on statutory grants of local autonomy and police power, and the ordinance must not conflict with national law.

E. Government-Owned or -Controlled Corporations

GOCCs combine public purpose with corporate form.

Implication: Administrative law issues often arise in procurement, public funds, accountability, and when a GOCC regulates or exercises delegated powers.

VIII. Classifications by Procedure

A. Rule-Making Procedure vs Adjudicatory Procedure

Rule-making: policy and standard-setting; often more open-ended but must satisfy effectivity requirements and reasonableness.
Adjudication: case-based; requires administrative due process, substantial evidence, and a clear record.

B. Formal vs Informal Administrative Processes

Formal processes resemble trial-type hearings (witnesses, evidence, record).
Informal processes include conferences, position papers, compliance submissions, inspections.

Why it matters: The nature of process affects what courts will require and what constitutes sufficient due process in context.

C. Publication/Effectivity-Based Classification of Issuances

A major Philippine distinction is between issuances that must be published (because they affect the public) and those that are mainly internal. Relatedly:

some issuances require filing or dissemination and have defined effectivity dates;
others are effective upon issuance if internal and non-public facing.

Why it matters: Failure to satisfy effectivity requirements can render a rule unenforceable against the public.

IX. Classifications by Standard of Judicial Review and Evidentiary Thresholds

A. Review of Quasi-Judicial Findings: Substantial Evidence Rule

Administrative findings of fact are generally respected when supported by substantial evidence—that relevant evidence which a reasonable mind might accept as adequate to support a conclusion.

Why it matters: Parties attacking agency findings must show not mere error, but that the decision lacks the required evidentiary basis, or that the agency acted arbitrarily or beyond jurisdiction.

B. Review of Legal Questions: Correctness with Deference

Courts decide legal questions, but may defer to specialized agency interpretation when the statute is technical and the agency’s interpretation is consistent and reasonable.

Why it matters: Classification as “technical” or “specialized” can influence how much persuasive weight an agency interpretation gets.

C. Review for Grave Abuse of Discretion

Courts may set aside administrative acts for grave abuse of discretion—arbitrary or despotic exercise of judgment amounting to lack or excess of jurisdiction.

Why it matters: This is a central constitutional safety valve against administrative overreach.

X. Classifications by Remedies and the Review Path

A. Internal Administrative Remedies vs Judicial Remedies

Administrative law distinguishes:

internal remedies: motion for reconsideration, administrative appeal, review by department head, board, commission, or Office of the President where applicable;
judicial remedies: petitions and appeals to courts (often after exhaustion).

Why it matters: The doctrine of exhaustion of administrative remedies generally requires using available agency remedies before going to court, subject to recognized exceptions (e.g., pure legal issues, irreparable injury, patent illegality, lack of jurisdiction, futility, or when administrative remedy is inadequate).

B. Primary Jurisdiction

Even when courts have jurisdiction, they may defer initial determination to the agency on matters within the agency’s specialized competence.

Why it matters: Classification of an issue as “technical” or within an agency’s “special competence” often triggers this doctrine.

C. Finality Doctrine

Courts typically require a final agency action before review.

Why it matters: It prevents premature suits and respects administrative processes, but cannot be used to shield unlawful acts.

XI. Substantive Classifications of Administrative Due Process in the Philippine Setting

Philippine administrative law often frames due process in two overlapping classifications:

A. Procedural Due Process in Administrative Proceedings

This generally requires:

notice,
opportunity to explain and be heard,
consideration of evidence,
decision supported by evidence and disclosed reasons.

The precise “trial-type” formality varies by context; agencies may adopt more flexible procedures, but must remain fundamentally fair.

B. Substantive Due Process and Reasonableness

Even with perfect procedure, a regulation can be invalid if it is:

arbitrary,
oppressive,
not reasonably related to a legitimate governmental purpose,
discriminatory without sufficient justification.

Why it matters: This is often the lens for challenges to regulatory burdens, licensing conditions, and enforcement measures.

XII. Practical Synthesis: Why These Classifications Matter

A single administrative controversy often involves multiple classifications at once:

If an issuance is labeled a “memorandum,” but it binds the public and imposes new obligations, courts may treat it as a legislative rule and require full compliance with effectivity requirements and delegation limits.
If an agency “investigation” effectively determines liability and imposes sanctions, due process protections associated with quasi-judicial adjudication become crucial.
If a party runs to court too early, the finality, exhaustion, and primary jurisdiction classifications may bar the case—unless an exception applies.
If a statute delegates broad power without clear standards, the classification as delegated legislative power raises the non-delegation issue.

In short: classification is not merely academic. It is often the decisive step in determining:

whether the agency had authority,
what procedure was required,
when and how the action becomes effective,
what evidence is needed, and
what remedy is proper.

XIII. Common Exam- and Practice-Ready Classification Map

To make the topic operational, Philippine administrative law can be “mapped” in a compact checklist:

Source

Constitution / Statute / Issuance / Jurisprudence / Local regulation

Agency Type

Department / Independent regulator / Constitutional commission / GOCC / LGU

Function

Quasi-legislative / Quasi-judicial / Executive-enforcement

Form of Action

Rule / Order / License / Sanction / Investigation / Advisory / Internal guideline

Process

Publication & effectivity?
Notice and hearing?
Formal hearing or paper submissions?
Record and findings?

Review/Remedy

MR/appeal required? Exhaustion?
Final action?
Standard of review: substantial evidence / legality / grave abuse?

Using this map forces clarity and prevents the most common analytical error: treating all agency acts as if they were the same kind of governmental action.

XIV. Conclusion

“Classifications of administrative law in the Philippines” is best understood as a set of interlocking classifications that identify: the legal source of administrative power, the institution exercising it, the function being performed, the type of act produced, the procedure required, and the mode and standard of review. Each classification carries concrete legal consequences—especially for validity, effectivity, due process, deference, and remedies.

Administrative law, at its core, is the law that makes the modern regulatory state both effective and accountable—and classifications are the doctrinal tools that let lawyers, judges, and students determine when regulation is lawful, when it becomes binding, and how it can be challenged or defended.