The doctrine of exhaustion of administrative remedies provides that "where an administrative remedy is provided by statute, relief must be sought from the administrative body and this remedy exhausted before the courts will act." (Abelleira v. District Court of Appeal (1941) 17 Cal. 2d 280, 292.) "The doctrine of exhaustion of administrative remedies was evolved by the courts to promote comity between coequal branches of government and to relieve overburdened courts from the need to deal with cases where effective administrative remedies are available. (Bozaich v. State of California (1973) 32 Cal. App. 3d 688, 698 . . . .)" (Patane v. Kiddoo (1985) 167 Cal. App. 3d 1207, 1214.) The doctrine prevents interference with the subject matter jurisdiction of another tribunal where an administrative tribunal was created by law to adjudicate the issue sought to be presented to the court and claim is within the special jurisdiction of the administrative tribunal. (See Rojo v. Kliger (1990) 52 Cal. 3d 65, 85.) The doctrine presupposes that an administrative authority and a court both have jurisdiction over a matter. The doctrine "is a fundamental rule of procedure laid down by courts of last resort, followed under the doctrine of stare decisis, and binding upon all courts." (Abelleira v. District Court of Appeal, supra, 17 Cal. 2d at p. 293.) "Exhaustion of the administrative remedy is a jurisdictional prerequisite to resort to the courts" for purposes of determining right to restraint by writ of prohibition. (Ibid.) As the court in Green v. City of Oceanside, supra, 194 Cal. App. 3d 212, astutely observed, "the association of the exhaustion doctrine with the 'jurisdiction' of the superior court has led to some confusion. At least one court assumed that jurisdiction in this context refers to subject matter jurisdiction and, relying on the venerable rule that subject matter jurisdiction may not be waived by a party or conferred on the court by consent , concluded that the failure to exhaust administrative remedies 'may be challenged at any stage of the proceeding.' " (Id. at p. 220.) The Green court rejected the notion that the exhaustion doctrine affected the fundamental subject matter jurisdiction of the court: "Abelleira makes it abundantly clear that the exhaustion doctrine does not implicate subject matter jurisdiction but rather is a 'procedural prerequisite' originally devised for convenience and efficiency' and now 'followed under the doctrine of stare decisis, . . .' (Id. at pp. 288, 291.) It is 'jurisdictional' only in the sense that a court's failure to apply the rule in a situation where the issue has been properly raised can be corrected by the issuance of a writ of prohibition." (Id. at p. 222, italics in original.) The court in Mission Housing Development Co. v. City and County of San Francisco, supra, 59 Cal. App. 4th 55, found the reasoning in Green persuasive and applied its holding without further analysis to the taxpayers' failure to file valid applications for reduction in assessment. (Id. at pp. 67-68.) In Luce v. City of San Diego (1926) 198 Cal. 405, the California Supreme Court explained: "In the early case of Fall v. Marysville (1861) 19 Cal. 391, it was held by this court that an objection to a tax assessment which did not go to the validity of the tax itself but simply as to its amount must be made to the proper tribunal for reduction before an action would lie to restrain the collection of such a tax. In the case of Henne v. Los Angeles County (1900) 129 Cal. 297 . . ., the foregoing doctrine was extended so as to be given application to an assessment of property which was not assessable, as in that case to the imposition of a tax upon a mortgage held by the University of California and taxed against the owner of the property in question. In the later case, however, of Brenner v. Los Angeles (1911) 160 Cal. 72 . . ., this court drew the distinction between the wrongful assessment of property not subject to taxation and the wrongful valuation of taxable property, and to the extent only of an attempted assessment of nontaxable property overruled its former decision in the case of Henne v. Los Angeles County, supra; but otherwise indicated that the rule laid down in the earlier cases above referred to was to be upheld in its application to an unequal assessment of taxable properties. We are entirely satisfied that the rule as thus limited has full application to such cases as are presented upon the present appeals and that in the absence of a showing that the complaining property owners have made due application to the city board of equalization for relief from the arbitrary and unequal valuations of the assessor the plaintiffs herein were not entitled to a recovery of the taxes paid, even though they had in each case made such payment under protest as provided in former section 3819 et seq. of the Political Code." (Luce v. City of San Diego, supra, 198 Cal. at pp. 406-407.)