Case Digest (G.R. No. 157494)
Facts:
Bacolod City Water District v. The Hon. Emma C. Labayen, G.R. No. 157494, December 10, 2004, Supreme Court Second Division, Puno, J., writing for the Court.Petitioner Bacolod City Water District (BACIWA), a government-owned and controlled corporation created under Presidential Decree No. 198, published on January 15, 1999 a schedule of automatic water-rate adjustments to take effect January 22, 1999 (later suspended) and then announced implementation on April 1, 1999. The City of Bacolod (respondent), a municipal corporation under Commonwealth Act No. 326, filed on March 26, 1999 an action for injunction with a prayer for temporary restraining order (TRO) and/or preliminary mandatory injunction in the Regional Trial Court (RTC), Branch 46, seeking to enjoin BACIWA’s rate increase on grounds including absence of the public hearing required by public issuances.
The RTC set preliminary hearings, required memoranda (April 8, 1999), and received extensive submissions by BACIWA, including evidence of public hearings held in 58 of 61 barangays. BACIWA moved to dismiss (May 5, 1999) arguing lack of jurisdiction and failure to exhaust administrative remedies. The RTC denied extensions, received affidavits and documentary evidence, and—after further motions and intermittent proceedings—issued on February 24, 2000 an order directing BACIWA “to stop, desist and refrain” from implementing the new rates then scheduled to start March 1, 2000; the order referred to Administrative Circular No. 6 and the Rules of Court.
BACIWA moved to dissolve/reconsider the TRO and filed other motions; hearings and orders followed through March–April 2000. The RTC later denied BACIWA’s motion to dismiss (April 10, 2000). On December 21, 2000 the RTC issued a Decision granting a final injunction (stating it was “confirming the preliminary injunction previously ordered”). BACIWA moved for reconsideration (filed January 11, 2001) and the RTC denied it (January 24, 2001).
BACIWA filed a special civil action for certiorari under Rule 65 in the Court of Appeals (CA), which dismissed the petition, construing the RTC’s February 24, 2000 order as a preliminary injunction of semi-permanent effect and upholding the RTC’s final injunction (CA Decision...(Subscriber-Only)
Issues:
- Did the trial court act without or in excess of jurisdiction and/or with grave abuse of discretion in issuing a final injunction despite procedural deficiencies (no answer filed, no joinder of issues, no mandatory pre-trial, no trial on the merits)?
- Was the RTC Order dated February 24, 2000 a temporary restraining order or a preliminary injunction?
- Did the Court of Appeals err in dismissing BACIWA’s certiorari petition, thereby effectively preventing p...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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