Title
Chief of the Philippine Constabulary vs. Court of 1st Instance of Rizal
Case
G.R. No. L-22308
Decision Date
Mar 31, 1966
Municipal ordinances allowing cockfights on non-specified days were declared null and void, as local governments cannot override national laws regulating cockfighting.

Case Digest (G.R. No. L-22308)
Expanded Legal Reasoning Model

Facts:

  • Background and Applicable Ordinances
    • The cases revolve around municipal ordinances purportedly authorizing licensed cockpits to conduct cockfights on days other than those specified in Sections 2285 and 2286 of the Revised Administrative Code.
    • One ordinance of the City of Caloocan (Ordinance No. 7, Series of 1962) empowered the mayor to allow cockfights on ordinary days, not exceeding three days per week, in addition to the legal holidays and local fiesta celebrations.
    • Similar ordinances were enacted by local government units in Paranaque (Ordinance No. 3, Series of 1962) and Pasay City, which provided that cockfighting could also be held on additional ordinary days (up to six days a month in Paranaque) subject to the payment of a fee to support specific municipal funds.
  • Initiation of Litigations
    • In Caloocan, Leon Roque, operator of the Grace Park Cockpit, sought relief after the Chief of the Philippine Constabulary and other officers interfered with the operation of cockfights on an authorized ordinary day (Wednesday, June 2, 1962).
    • Roque initially instituted Civil Case No. 7170 to recover damages and obtain a writ of preliminary injunction; although the injunction was denied by Judge E. Mencias, Roque later revived his claim by filing Civil Case No. 6-C seeking a restraining order against further interference.
    • On August 14, 1963, Judge Gabriel V. Valero issued a writ of preliminary injunction in favor of Roque, a decision which was later set aside following a series of procedural maneuvers including motions to dismiss and reconsideration requests.
  • Procedural History and Developments
    • After the initial controversy in Caloocan, further actions were taken by Leon Roque and other cockpit operators when municipal ordinances in Paranaque and Pasay City permitted cockfighting beyond the days stipulated by the Revised Administrative Code.
    • In Paranaque, operators Candido Ignacio and Claro Cortez filed Civil Case No. 436-R, later revived as Case No. 442-R, to restrain the Constabulary and to secure a ruling declaring the municipal ordinance valid and binding. An ex-parte writ of preliminary injunction was issued by Judge Pedro Jl. Bautista.
    • In Pasay City, Pilar O. Santiago instituted similar proceedings (Civil Case No. 2309-P, later revived as Civil Case No. 2330-P) to prevent interference with the operation of the Pasay Cockpit on normally unauthorized days. Her case initially saw the denial of a writ of preliminary injunction before being revived.
    • In response to these multiple litigations and the issuance of injunctive relief orders by lower courts (notably by Judge Bautista), top government officials—the Chief of the Philippine Constabulary, the Provincial Commander of Rizal, and the Secretary of National Defense—filed actions in the Supreme Court. These suits sought to annul the injunctions and dissolve the orders that allowed operations on days exceeding the statutory limitations.
  • Consolidation and Intervention by the Supreme Court
    • The three principal cases (G.R. Nos. L-22308, L-22343, and L-22344) became the vehicle through which the dispute over the validity of the municipal ordinances and the conduct of local courts was examined.
    • Despite various motions to dismiss by Roque and the affected cockpit operators over time, the issues were considered sufficiently similar to warrant a consolidated examination by the Supreme Court concerning the authorization of cockfighting on days other than those allowed by law.

Issues:

  • Whether municipal ordinances that authorize cockfighting on days other than those expressly permitted by Sections 2285 and 2286 of the Revised Administrative Code can be deemed valid.
  • Whether the issuance of preliminary injunctions by lower courts, effectively allowing cockpits to operate on unauthorized days, amounts to an abuse of judicial discretion.
  • Whether local governments have the constitutional and statutory authority to regulate cockfighting beyond the limitations expressly provided by national law.
  • Whether the actions and orders of the lower courts, including the issuance and non-dissolution of injunctions despite prior Supreme Court precedent (as in the Quimsing case), have undermined the executive department’s duty to enforce national law.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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