G.R. No. 7094 - People vs. De la Cruz

The City of Manila, through Treasurer Liberty M. Toledo, assessed private respondents (SM Mart, Inc.; SM Prime Holdings, Inc.; Star Appliances Center; Supervalue, Inc.; Ace Hardware Phils., Inc.; Watsons Personal Care Stores Phils., Inc.; Jollimart Phils. Corp.; Surplus Marketing Corp.; Signature Lines) for 2002 local business taxes under Sections 14–21 of the Revised Revenue Code of Manila (RRCM), amounting to ₱19,316,458.77.
Payment of the assessed taxes was a precondition for issuance of business permits, and respondents paid under protest.

On January 24, 2004, respondents filed a complaint for refund of illegally collected taxes with RTC Branch 112, Pasay City, alleging double taxation under Section 143(h) of the Local Government Code and unconstitutionality of amended RRCM provisions.
The RTC granted a writ of preliminary injunction on July 9, 2004, enjoining collection under Section 21 RRCM; denied petitioners’ motion for reconsideration on October 15, 2004.
Petitioners sought certiorari under Rule 65 before the Court of Appeals (CA); the CA dismissed for lack of jurisdiction on April 6, 2006, and denied reconsideration on November 29, 2006.
Meanwhile, on August 13, 2007, the RTC rendered a final decision granting respondents the full refund (₱19,316,458.77); the decision became final and executory October 20, 2008; writ of execution issued November 25, 2009.

Did the CA err in dismissing the certiorari petition for lack of jurisdiction?
Did the RTC gravely abuse its discretion in issuing the preliminary injunction enjoining Section 21 RRCM?
Did the RTC err in granting an injunction despite respondents’ failure to file a written refund claim?
Was the RTC’s injunction improper given that the City was a mere collecting agent under Section 21?
Did the injunction impose greater damage and prejudice on petitioners and their constituents?