Case Digest (G.R. No. L-15760)
Facts:
The case involves The Butuan Lumber Manufacturing Co., Inc. and several individuals as petitioners against Hon. Montano Ortiz and others as respondents. The events leading to this case began with a boundary dispute between Rafael C. Aquino and the Butuan Lumber Manufacturing Co., Inc. concerning a forest concession located along the Davao-Agusan Road in Agusan province. The conflict arose when a forest guard, Cipriano M. Medina, conducted a survey of the Maygatasan-San Salvador Trail, which was found to pass through the middle of Aquino's concession. The Butuan Lumber Manufacturing Co. sought to log in the area east of the trail, leading to tensions as they prohibited Aquino from logging in the adjacent area.
On June 25, 1958, the Director of the Bureau of Forestry ordered a suspension of logging operations pending verification. A subsequent survey by Forester Juan indicated that the trail's location differed from Medina's findings, prompting the Bureau to amen...
Case Digest (G.R. No. L-15760)
Facts:
Background of the Case
- Rafael Aquino and Zacarias Aquino (petitioners in the lower court) held a forest concession in Agusan, bordering a concession operated by Butuan Lumber Manufacturing Co., Inc. (petitioners in this case).
- A boundary dispute arose between the two concessions, specifically regarding the Maygatasan-San Salvador Trail, which was surveyed by forest guard Cipriano M. Medina.
Administrative Proceedings
- On June 25, 1958, the Director of the Bureau of Forestry, Amos, ordered the suspension of logging operations pending verification by Forester Juan.
- Forester Juan conducted a survey and found that the trail was not as indicated by Medina, leading to an amendment of the boundary of Aquino's concession.
Filing of the Case
- On October 28, 1958, Aquino filed Special Civil Case No. 62 in the Court of First Instance of Agusan, seeking a preliminary injunction against Butuan Lumber Manufacturing Co., Inc. and others.
- Aquino alleged that:
- They had been logging in the disputed area since 1956.
- Respondents entered the area, threatened Aquino's workers, and stopped operations.
- The Bureau of Forestry initially suspended operations but later rectified the boundary, confirming Aquino's claim.
- Respondents continued to interfere, forcing Aquino to log elsewhere, causing financial losses.
Motions to Dismiss
- Respondents filed two motions to dismiss, arguing:
- The petition lacked a cause of action because administrative remedies had not been exhausted (an appeal to the Secretary of Agriculture and Natural Resources was pending).
- The court lacked jurisdiction over the subject matter.
- The lower court denied both motions, holding that the grounds for dismissal were not indubitable and should be resolved after trial.
Issue:
- Whether the lower court had jurisdiction to entertain Aquino's petition for a preliminary injunction despite the pending administrative appeal.
- Whether the lower court committed grave abuse of discretion in denying the motions to dismiss and proceeding with the case.
- Whether the issuance of a preliminary injunction was proper under the circumstances.
Ruling:
The Supreme Court dismissed the petition for certiorari, holding that:
- The lower court had jurisdiction to entertain Aquino's petition for a preliminary injunction.
- The lower court did not commit grave abuse of discretion in denying the motions to dismiss.
- The petition for a preliminary injunction was sufficient, and the lower court acted correctly in requiring respondents to answer and setting the case for trial.
Ratio:
- (Unlock)