G.R. No. 192809 - Bureau of Customs vs. Court of Appeals, Cagayan de Oro Station

The consolidated petitions involve the Bureau of Customs (BOC), Atty. Anju Nereo C. Castigador (OIC-District Collector, Port of Davao), and Reta, owner and operator of Aquarius Container Yard (ACY).
ACY, approved by the BOC in 2006 for container yard operations outside the customs territory, became the focal point of the dispute.
In January 2009, Reta entered into a Memorandum of Agreement (MOA) with the BOC whereby his container yard was designated as the examination area for container vans at the Port of Davao for a period of 25 years, with a provision allowing either party to revoke the MOA for cause.

On February 26, 2010, the BOC alleged that Reta closed ACY and barred customs examiners from entering the premises.
That same day, Atty. Castigador notified Reta, via a letter, of the intention to conduct examinations at the Philippine Ports Authority (PPA) premises in Sasa, Davao City, signaling a reassessment of the MOA as its purpose was rendered moot.
Reta responded by filing a Complaint with an Application for a Preliminary Injunction and Prayer for a Temporary Restraining Order (TRO) against the petitioners, claiming that after the original consent to use ACY, he had invested in various machineries and equipment for container examination.
The Complaint sought:

A restraining order or injunctive relief.
Nullification of Atty. Castigador’s February 26, 2010 letter on due process grounds and as a violation of the MOA.
Enforcing the parties’ obligations under the MOA.
Payment of damages, attorney’s fees, and costs.

The Regional Trial Court (RTC) initially granted a TRO to prevent the BOC from removing container vans in ACY and to direct the resumption of operations there.
After re-raffling the case from Judge Carpio to Judge Omelio following a granted motion for inhibition, the RTC, on April 19, 2010, issued a writ of preliminary injunction. This order:

In G.R. No. 192809, the Court of Appeals (CA) issued a July 22, 2010 Resolution denying petitioners’ application for injunctive relief regarding the RTC order.
In G.R. Nos. 193588 and 193590-91, Atty. Castigador’s petition for certiorari challenged the RTC’s omnibus order that denied his motion for inhibition, granted Reta’s petitions for indirect contempt, and issued a warrant of arrest against him.
In G.R. No. 201650, petitioners assailed the CA’s January 17, 2012 Decision and April 17, 2012 Resolution dismissing their Petition for Certiorari challenging the RTC order.

The dispute centers on whether the MOA could be revoked by the BOC and whether the issuance of the writ of preliminary injunction by the RTC was appropriate.
Petitioners argued that:

The RTC’s injunction improperly interfered with the BOC’s functions.
Reta’s alleged closure of ACY was not instigated by petitioners as he claimed.
Reta had not suffered irreparable injury since his claim for damages was quantifiable.

That his investments in ACY warranted protection.
That petitioners’ actions – including the alleged closure of ACY and subsequent letter by Atty. Castigador – were unjust and lacked due process.
Matters extraneous to the injunction issue were raised, such as administrative and potential criminal proceedings against Atty. Castigador, although these points were deemed irrelevant to the core dispute.

Whether the Court of Appeals erred in not finding grave abuse of discretion on the part of the RTC in issuing a writ of preliminary injunction in favor of Reta.

The central controversy is the propriety of the writ of preliminary injunction granted on April 19, 2010, which prevented the BOC from revoking the MOA and from shifting examination operations to the PPA premises.
Whether Reta possessed a clear and unmistakable right to continue the customs operations in ACY despite the BOC’s authority to revoke the MOA for cause.
The issue of irreparable injury to Reta in the absence of a properly established right, considering that any alleged damages appeared quantifiable.
The application of the principles governing the issuance of a writ of preliminary injunction and the demonstration (or lack thereof) of the requisite conditions under Rule 58 of the Rules of Court.