Facts:

The case involves Austin Hardware Company, Inc. and All Steel Products, Inc. as petitioners against the Court of Appeals, Elenita H. Manzano, and Francisco Inocencio as respondents. The events surrounding the case date back to September 9, 1969, when the Mayor of San Juan, Rizal, issued a business license allowing Austin Hardware Company, Inc. to engage in the general hardware manufacturing business at No. 115 Lope K. Santos St., San Juan, Rizal. Subsequently, on July 7, 1970, All Steel Products, Inc. was similarly granted a license for manufacturing steel products at the same location. By 1974, both companies had significantly invested in their operations. However, complaints surfaced starting from September 19, 1973, from the Parents-Teachers Association of Pedro Cruz Elementary School and local residents, alleging that the businesses created nuisances including noise, disturbances to classes, air pollution, and fire hazards. Following these grievances, the Mayor referred the

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Facts:

Background and Licensing

• On September 9, 1969, the Mayor of San Juan, Rizal, issued a business license to Austin Hardware Company, Inc. authorizing it to engage in the manufacture of general hardware at No. 115 L. K. Santos St.
• On July 7, 1970, the same Mayor issued a business license to All Steel Products, Inc. to engage in the manufacture of steel products at the same location.
• In compliance with these licenses, the petitioners invested significant capital and commenced operations according to the terms set in the permits.

Complaints and Allegations of Nuisance

• On September 19, 1973, the Parents-Teachers Association of Pedro Cruz Elementary School sent a letter to the Mayor alleging that:
• The heavy trucks used by the petitioners caused traffic congestion on a narrow street.
• Horns and operational noise disturbed classes.
• Unloading of steel bars created excessive noise.
• Foul odors and emissions from the site resulted in air pollution.
• Potential storage of chemicals posed fire hazards to the school and nearby residences.
• On September 20, 1973, other local residents submitted a similar complaint highlighting issues with a faulty drainage system causing seepage and nighttime noise from the warehouse.
• On September 26, 1973, private respondent Elenita H. Manzano also lodged a complaint with the Mayor regarding the alleged nuisances.

Investigation and Administrative Response

• Acting on the multiple complaints, the Mayor referred the matter to the Municipal Engineer, the Municipal Health Officer, and the Municipal Council.
• The Municipal Council, by Resolution No. 228 dated October 25, 1973, referred the case for verification to the National Pollution Control Commission.
• The Commission’s mechanical engineers recorded noise levels (56 dB for Austin Hardware and 52 dB for All Steel Products during daytime) and remarked that construction activities could generate noise above normal residential levels.
• The recommendations included caution in issuing permits for industrial or manufacturing purposes in residential areas.

Decision and Revocation of Permits

• On February 13, 1974, the Municipal Council rendered its decision:
• Affirming the validity of Austin Hardware Company, Inc.’s original license.
• Directing that the Mayor cancel or revoke the permits for manufacturing activities of both Austin Hardware Company, Inc. and All Steel Products, Inc., based on the provisions of Section 2194 of the Revised Administrative Code.
• Consequently, the Mayor sent a letter to the petitioners advising that:
• The license or permit for manufacturing operations (including applications dated September 8, 1969, July 7, 1970, and Permit No. JR-73-1145 dated January 31, 1973) was canceled or revoked effective five days from receipt.
• Motions for reconsideration by the petitioners were denied.

Judicial Proceedings and Injunctions

• Petitioners initiated an ordinary action for injunction in the Court of First Instance (Civil Case No. 19233) alleging that the revocation of their manufacturing permits violated procedural due process.
• The presiding Judge, Gregorio G. Pineda, issued a restraining order enjoining the Mayor and municipal officers from enforcing the cancellation of permits relating to:
• The construction of the warehouse or bodega.
• The operation of the hardware business and the steel manufacturing facility.
• Private respondents intervened and moved to lift the restraining order, which was subsequently denied by the court on September 5, 1974, with a motion for reconsideration also denied.
• On March 17, 1975, the Court of Appeals, in its resolution, issued a writ of preliminary injunction restraining:
• The respondent judge from continuing Civil Case No. 19233.
• The private respondents from continuing the construction, the hardware business, and the steel manufacturing operations at the specified location.
• Private respondents, on March 19, 1975, filed a petition citing petitioners for contempt due to noncompliance with the writ.

Evidentiary Findings and On-site Observations

• During the April 16, 1975, oral arguments, petitioners contended that the injunction should not extend to their hardware operations as their license for a hardware store remained unaffected.
• The Appellate Court found no merit in their contention, based on evidence from an on-site inspection conducted by the Deputy Clerk of Court (Atty. Catalina C. Buena) together with the attorneys of both sides:
• Approximately twenty major machines were observed connected and ready for operation.
• Signs of recent manufacturing activity were evident (active welding, steel cutting, freshly painted areas, and hot metal parts).
• Consistent operation of equipment, including forklifts and heavy machinery, produced loud disturbances and vibrations.
• The evidence confirmed that the petitioners continued operating their hardware and manufacturing business despite the injunction.

Contempt Proceedings and Appellate Resolution

• The Court of Appeals, in its resolution on August 19, 1975:
• Held petitioners in contempt for willfully disobeying the clear injunction order.
• Imposed a fine of P500.00.
• Dismissed the contention regarding the separate permit for a hardware store, noting the absence of such evidence.
• As a result, the petition for certiorari and prohibition was dismissed, along with any relief prayed for by the petitioners, and costs were charged against them.

Issue:

Jurisdiction and Scope of Injunction

• Whether the Court of Appeals exceeded its jurisdiction by enjoining the respondent judge from continuing proceedings in Civil Case No. 19233.
• Whether the injunction properly extended to restraining the construction of a commercial house and the operation of both a hardware business and a steel manufacturing facility.

Permit Validity and Interpretation

• Whether the petitioners’ assertion of a separate hardware store permit – not subject to revocation – was valid.
• Whether the absence of a separately evidenced hardware store license negated the scope of the injunction.

Due Process Considerations

• Whether the revocation of the permits violated the requirements of procedural due process by relying on nuisance complaints not strictly confined to zoning ordinance violations.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)