Case Digest (G.R. No. 214073) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bicol Medical Center, represented by Dr. Efren SJ. Nerva, and the Department of Health, represented by Health Secretary Enrique T. Ona (petitioners), the dispute arose over Road Lot No. 3, a service road originally part of Camarines Sur Provincial Hospital’s premises in Naga City. In 1982, the Provincial Government donated roughly five hectares, including Road Lot No. 3, to the Ministry of Health, as evidenced by Transfer Certificate of Title No. 13693. The road, which had been used by hospital personnel and, allegedly, by the public, was closed to vehicular and pedestrian traffic by BMC in April 2012 under Hospital Memorandum No. 0310 and secured by a steel gate. Local residents led by Atty. Noe Botor and others (intervenors) petitioned the Regional Trial Court (RTC) of Naga City for a writ of preliminary injunction to compel the reopening of the road. The RTC denied the application on the ground that the public failed to prove a clear and unmistakable right to the road. On ... Case Digest (G.R. No. 214073) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Establishment and Land Donation
- 1933: Camarines Sur Provincial Hospital established in Naga City; later converted to Bicol Regional Training and Teaching Hospital and ultimately Bicol Medical Center (BMC) in 1995.
- 1982: Provincial Government donated about five hectares, including Road Lot No. 3, to the Ministry of Health (now Department of Health) under TCT No. 13693.
- Gate Installation and Closure
- 2009: BMC installed a steel gate on J. Miranda Avenue to control traffic.
- March 21, 2012: Chief Dr. Nerva issued Mem. No. 0310 rerouting traffic inside BMC; closed eastern gate effective April 1, 2012, for security and development.
- May 19, 2012: Atty. Botor petitioned Naga City Mayor to dismantle the gate as a public nuisance; City Council authorized dismantling but Mayor filed injunctive petition instead.
- Procedural History
- Dec. 21, 2012 & Feb. 22, 2013: RTC denied Naga City’s application for injunctive relief and its motion for reconsideration.
- Feb. 28, 2014 & Aug. 26, 2014: Court of Appeals granted certiorari, held respondents made prima facie showing of public character of Road Lot No. 3, directed RTC to issue writ of preliminary injunction; denied motions for reconsideration.
- Sept. 29, 2014–Oct. 8, 2014: BMC and DOH filed petition for review; Supreme Court issued TRO; parties filed comments and replies.
Issues:
- Did the Court of Appeals err in directing the RTC to issue a writ of preliminary injunction against BMC’s closure and relocation of Road Lot No. 3?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)