G.R. No. 82189 - Auxilio, Jr. vs. National Labor Relations Commission

Corazon Y. Lua was lawfully engaged in the business of supplying crushed aggregates and mixed sand and gravel quarried from Camp 2, Talisay, Cebu.
She operated under permits issued by the Bureau of Mines and had constructed necessary infrastructure, including leasing property from Paulino Abatayo to build roads for accessing her quarry and operating her rock crusher machine.

On February 25, 1980, while Lua’s trucks were loading and hauling crushed aggregates at her quarry, the defendants—Desamparado C. Crystal and D.C. Crystal, Inc.—alleging that Lua’s area of operations was within their concession, intervened.
The defendants used a bulldozer to destroy the road built by Lua on her leased right-of-way and also demolished another road connecting her rock quarry to the Mananga River.
The destruction resulted in Lua’s employees being denied access to her operations, immobilizing her key machinery including three payloaders, eight dump trucks, a rock crusher machine, and trucks of a third party (Geo-Transport, Inc.).

In her verified complaint filed under Civil Case No. AV-433, Lua alleged that the defendants’ actions caused her irreparable injury by hindering her business operations and causing significant financial loss.
Based on Lua’s sworn averments—including the estimated P20,000.00 cost of road restoration, daily loss figures, and the interference with her business—the respondent Judge issued a temporary restraining order on February 26, 1980.
The Order mandated that the defendants immediately cease and desist from disturbing Lua’s operations pending a hearing, which was set for March 4, 1980, at 8:30 in the morning.
Subsequently, at a hearing (which included an ocular inspection at Camp 2, Talisay, with representatives from the Bureau of Mines), the trial court received oral arguments and evidence from the parties.

One for dismissal of the case on the grounds of improper venue and the alleged absence of a valid cause of action.
Another for the dissolution of the restraining order, arguing that Lua had no right to the relief demanded and that, in effect, she was the one infringing on the defendants’ rights.

After a thorough hearing on the motions, the respondent Judge denied both motions in an Order dated March 24, 1980.

On April 14, 1980, D.C. Crystal, Inc. commenced a special civil action in this Court seeking the issuance of the extraordinary writs of certiorari and prohibition to annul and permanently inhibit the enforcement of the earlier orders (both the temporary restraining order and the preliminary injunction).
The petitioner advanced several arguments:

It claimed that its mining activities, under placer mining lease contracts governed by PD No. 605 and PD No. 1281, were immune from judicial intervention via restraining orders.
It contended that venue was improperly determined, insisting that the proper forum was in Cebu City rather than Mandaue City.
It argued that Lua’s verified complaint failed to state a valid cause of action since the underlying lease was allegedly not in her name but in that of the Kimwa Development Corporation, and because of her Chinese nationality, which supposedly barred her from exploiting the country’s natural resources.
Additionally, petitioner sought to declare Lua in contempt for alleged forum shopping, noting that she had filed essentially identical cases in different branches of the court.

On April 18, 1980, the Court issued an order restraining the enforcement of the respondent Judge’s orders (both the temporary restraining order from February 26 and the preliminary injunction from March 24), as well as restraining further proceedings in Civil Case No. AV-433—except for those concerning evidence on the alleged damages suffered by petitioner Crystal, Inc.
The subsequent evaluation of the defendant’s motions and the petitioner’s arguments led to further adjudication on issues of jurisdiction, venue, sufficiency of the alleged cause of action, and procedural compliance.

Whether the trial court had jurisdiction to issue a restraining order and preliminary injunction in a case involving mining operations, considering the provisions of PD No. 605 and PD No. 1281 which vest exclusive administrative control in the Bureau of Mines.
Whether the interference with Lua’s lawful business operations fell within the ambit of judicial intervention despite the alleged administrative nature of the dispute.

Whether the venue was correctly laid in Mandaue City based on the personal nature of the dispute, or if it should have been in Cebu City as the petitioner argued.

Whether the verified complaint, with its specific allegations of unlawful intrusion and destruction causing irreparable damages, sufficiently stated a valid cause of action even if external issues such as the lease contract’s name or Lua’s nationality were later raised by the petitioner.

Whether the petitioner’s failure to file a motion for reconsideration of the preliminary injunction before seeking certiorari constituted a fatal procedural omission.
Whether the allegations of forum shopping and the subsequent contempt motion against Lua were meritorious and properly grounded in the facts.