Title
Anacleto Trinidad vs. Moya
Case
G.R. No. L-16886
Decision Date
Apr 30, 1965
Petitioners challenged a preliminary injunction halting their collection of market rents, alleging political motives; SC upheld the injunction to prevent irreparable harm to the municipality.
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Case Digest (G.R. No. L-16886)

Facts:

The case involves a petition for certiorari filed by Anacleto Trinidad and Dionisio Barroga against the Municipality of Iriga, Camarines Sur, and Hon. Jose L. Moya, Presiding Judge of the third branch of the Court of First Instance of Camarines Sur. The petitioners sought to annul the trial court’s order dated March 22, 1960, in Civil Case No. 4836, which restrained them from collecting rents, fees, and other benefits from the Iriga Central Market and Sagrada Market during the pendency of the case.

Market Lease Agreements
On December 11, 1959, the Municipal Mayor of Iriga, Perfecto I. Tanduran, leased the Central Public Market to Anacleto Trinidad for P24,000.00 annually and the Sagrada Public Market to Dionisio Barroga for P360.00 annually. Both leases were for one year, extendible for another four years, subject to the approval of the Provincial Board. The Municipal Council approved these leases on December 29, 1959, and the lessees began operating the markets on January 1, 1960, after paying the first quarter’s rentals.

Allegations of Fraud and Collusion
On February 16, 1960, the Municipality of Iriga filed a complaint in the Court of First Instance of Camarines Sur to annul the lease agreements, alleging that the former Mayor Tanduran, in collusion with Trinidad and Barroga, leased the markets at unreasonably low rates, causing the municipality to lose approximately P11,000.00 annually. The complaint also stated that the municipality had been earning an average net income of P35,000.00 annually from the markets before the leases. The Municipality sought a writ of preliminary injunction to stop the petitioners from collecting rents and fees during the case's pendency.

Petitioners’ Defense
The petitioners argued that the lease agreements were lawful and advantageous to the municipality. They claimed the lawsuit was politically motivated by the incumbent municipal officials who, upon assuming office, passed a resolution annulling the leases without authority. They also filed a third-party complaint against the municipal officials for damages.

Preliminary Injunction
On March 22, 1960, the Court granted the writ of preliminary injunction ex-parte, finding that the continued collection of rents and fees by private individuals would cause irreparable injury to the municipality. The petitioners’ motion to set aside the injunction was denied, prompting them to file the present petition for certiorari.

Issue:

  1. Whether the trial court committed grave abuse of discretion in issuing the writ of preliminary injunction ex-parte.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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