Title
Secretary Proceso J. Alcala, et al. vs. Honorable Judge Emmanuel C. Carpio, et al.
Case
G.R. No. 211146
Decision Date
Apr 11, 2023
The Supreme Court nullified RTC-issued injunctions, ruling private respondents lacked NFA import licenses for rice shipments, failing to prove irreparable injury or clear legal right, upholding domestic laws over WTO obligations.
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Case Digest (G.R. No. 211146)

Facts:

Background of the Case

  1. Parties Involved: The petitioners are Secretary Proceso J. Alcala, as Secretary of the Department of Agriculture and Chairman of the National Food Authority (NFA) Council, and the Bureau of Customs (BOC), represented by Commissioner John Phillip P. Sevilla. The respondents are Honorable Judge Emmanuel C. Carpio (RTC Davao City) and Joseph Mangupag Ngo (in G.R. No. 211146), and Honorable Judge Cicero D. Jurado, Jr. (RTC Manila), Danilo G. Galang, and Ivy M. Souza (in G.R. No. 211375).

  2. Nature of the Case: The case involves two consolidated Petitions for Certiorari challenging the issuance of Writ of Preliminary Injunction by the RTC judges, which enjoined the BOC from seizing, holding, and detaining rice shipments imported without NFA import licenses.

Key Events

  1. Rice Shipments and NFA Import Licenses: In 2013, private respondent Joseph Mangupag Ngo entered into an agreement to purchase rice from Starcraft International Trading Corp. The rice shipments arrived at the port of Davao City but were withheld by the BOC due to the lack of NFA import licenses. Ngo argued that the import permits were unnecessary under the World Trade Organization (WTO) Agreement on Agriculture, which prohibits quantitative restrictions on agricultural imports.

  2. WTO Agreement on Agriculture: The Philippines, as a WTO member, had obtained a "Special Treatment" for rice, allowing it to impose quantitative restrictions until 2004, later extended to 2012. In 2012, the Philippines requested a further extension until 2017, which was pending approval at the time of the case.

  3. Domestic Laws on Rice Importation: Presidential Decree No. 4 (as amended) and Republic Act No. 8178 granted the NFA the authority to regulate rice importation, including issuing import permits. The NFA issued Memorandum Circular No. AO-2K13-03-003, requiring importers to secure import permits before importing rice.

  4. Injunction Proceedings: Ngo filed a Complaint for Permanent Injunction with a Prayer for Temporary Restraining Order (TRO) and/or Preliminary Injunction before the RTC Davao City, arguing that the withholding of his rice shipments caused him financial losses. The RTC granted the Writ of Preliminary Injunction, preventing the BOC from seizing the shipments. Similar injunctions were issued in favor of other private respondents (Galang and Souza) by the RTC Manila.


Issue:

  1. Whether the RTC judges committed grave abuse of discretion in issuing the Writ of Preliminary Injunction.
  2. Whether the private respondents had a clear and unmistakable right to import rice without NFA import licenses.
  3. Whether the private respondents would suffer irreparable injury if the injunction was not granted.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court ruled in favor of the petitioners, nullifying the Writ of Preliminary Injunction issued by the RTC judges. The Court emphasized the importance of adhering to legal requirements for injunctions and upheld the NFA's authority to regulate rice importation under domestic laws.


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