Facts:

The case involves Allied Domecq Philippines, Inc. (ADPI) as the petitioner against several respondents, including Hon. Sesinando E. Villon of the Regional Trial Court of Manila, Branch 23; Clark Liberty Warehouse, Inc.; and the Bureau of Customs and Bureau of Food and Drugs (BFAD). The events date back to May 8, 1996, when ADPI entered into an exclusive distributorship agreement with Pedro Domecq, S.A., a Spanish corporation, allowing ADPI to import and distribute various products including aFundadora brandy in the Philippines until May 17, 2000. This agreement stipulated automatic indefinite extension upon expiration. ADPI sought a Certificate of Registration from BFAD as per regulations requiring imported food products to be registered prior to distribution. On June 2, 1998, BFAD instructed the Bureau of Customs to forbid the entry of imported aFundadora brandy without a valid Certificate of Registration. In response, Customs issued Memorandum Circular No. 228-98 reflecting th

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Facts:

Exclusive Distributorship and Importation

• On May 8, 1996, Allied Domecq Philippines Inc. (ADPI) entered into an exclusive distributorship agreement with Pedro Domecq, S.A., a Spanish corporation engaged in manufacturing wine and brandy.
• Under the agreement, ADPI was granted the sole right to import and distribute various Pedro Domecq, S.A. products—including aFundadora brandy—in the Philippines until May 17, 2000, with an automatic extension thereafter for an indefinite period.

BFAD Registration and Customs Action

• ADPI applied for a Certificate of Registration with the Bureau of Food and Drugs (BFAD) in compliance with Department of Health Administrative Order No. 17, Series of 1979, which required registration of imported food products.
• On June 2, 1998, BFAD, through its then Director, informed the Bureau of Customs that shipments of aFundadora brandy should not be allowed entry unless accompanied by a valid Certificate of Registration, which led to the issuance of Customs Memorandum Circular No. 228-098 on July 13, 1998.

Importation by Clark Liberty and Seizure Proceedings

• On April 12, 1999, Clark Liberty Warehouse, Inc.—a duly licensed duty-free shop operating in the Clark Special Economic Zone (CSEZ)—imported 800 cases (totaling 9,420 bottles) of aFundadora brandy without the required BFAD Certificate of Registration.
• As a result, the Bureau of Customs seized and impounded the shipment pursuant to Customs Memorandum Circular No. 228-098 and the relevant provisions of the Tariff and Customs Code, initiating seizure proceedings before the District Collector of Customs, Port of Manila (docketed as S.I. No. 99-140).

Petitioner’s Interventions and Correspondence

• ADPI filed a motion to intervene in the ongoing seizure proceedings, alleging damages from Clark Liberty’s alleged illegal importation, but the motion was left unresolved by the Customs District Collector.
• On September 15, 1999, ADPI sent a cease-and-desist letter to Clark Liberty, demanding that they stop importing, distributing, selling, or marketing aFundadora brandy and refrain from participating in the seizure proceedings. Clark Liberty, however, did not comply with these demands.

Lower Court Proceedings

• On October 8, 1999, ADPI initiated a suit for injunction and damages in the Regional Trial Court (RTC) of Manila, Branch 23 (Civil Case No. 99-95337), seeking a temporary restraining order (TRO) and a writ of preliminary injunction.
• On August 15, 2000, the RTC denied the TRO and injunctive relief, holding that ADPI failed to prove unfair competition or bad faith on the part of Clark Liberty, and found no evidence of defectiveness or inferior quality in the product imported by Clark Liberty.
• ADPI’s subsequent motion for reconsideration was also denied on December 28, 2000.

Appeal and Jurisdictional Challenge

• On March 16, 2001, ADPI filed a special civil action for certiorari with the Court of Appeals (CA), docketed as CA-G.R. SP No. 63802, challenging the lower court’s decisions.
• On May 27, 2002, the CA dismissed ADPI’s petition on the ground of lack of jurisdiction, concluding that under Section 21 of Republic Act No. 7227, only the Supreme Court had the authority to issue a writ of injunction related to the conversion projects in the Clark Special Economic Zone.

Issue:

Jurisdictional Authority

• Whether the Court of Appeals erred in determining that it did not have jurisdiction over ADPI’s petition for certiorari based on Section 21 of Republic Act No. 7227.
• Whether the exclusive jurisdiction conferred by R.A. No. 7227 to the Supreme Court, regarding injunctions in matters related to the conversion of military reservations into productive civilian uses, bars the CA from exercising jurisdiction.

Merits of the Injunctive Relief

• Whether ADPI’s cause of action truly falls outside the ambit of projects governed by R.A. No. 7227, as ADPI contends that its claim for injunction does not relate to the conversion of military reservations.
• Whether the CA’s dismissal for lack of jurisdiction deprived the petitioner of the opportunity to have the merits of its claim properly examined.

Abuse of Discretion

• Whether the CA gravely abused its discretion by not addressing the merits of the petition for injunctive relief, even though it dismissed the case on a jurisdictional basis.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)