G.R. No. 199972 - De Lima vs. Court of Appeals

The Cagayan Economic Zone Authority (CEZA) granted Meridien Vista Gaming Corporation a license to conduct jai alai gaming operations within the Cagayan Special Economic Zone and Freeport (CSEZFP), including the establishment of off-fronton betting stations “in any place … as may be allowed by law.”
Shortly thereafter, the Office of the Government Corporate Counsel (OGCC) informed CEZA that it lacked the power to authorize, license, operate, or regulate jai alai absent an express legislative franchise.
Consequently, CEZA revoked Meridien’s license and directed the cessation of its gaming operations.
Meridien challenged the revocation before the Regional Trial Court (RTC) of Aparri, which issued a writ of mandamus directing CEZA “to allow [Meridien] to continue with its gaming operations in accordance with the license granted.”
The RTC’s decision ultimately lapsed into finality through the negligence of CEZA’s counsel, prompting CEZA to seek relief from judgment—a remedy denied both by the RTC and subsequently by the Court of Appeals (CA).

The Games and Amusement Board (GAB), through its Anti-Illegal Gambling Unit, investigated reported jai alai betting stations and discovered 13 off-frontons in Metro Manila and Rizal Province operating without permits.
GAB subsequently issued a show-cause order against the individuals responsible for these off-fronton operations, warning of criminal prosecution under Republic Act (RA) No. 954 and the closure of the establishments.
In response, Meridien filed a Complaint for Injunction before the RTC of Aparri, seeking a Temporary Restraining Order (TRO) and a Writ of Preliminary Injunction (WPI) to enjoin GAB’s Cease-and-Desist Order (CDO), contending that GAB had no regulatory authority over its gaming operations under the CEZA grant.
The RTC initially granted a 72-hour TRO later extended for 17 days before also issuing a WPI.
GAB then moved for the dismissal of the case on jurisdictional grounds, asserting that:

The RTC of Aparri did not have territorial jurisdiction since the off-fronton operations were located in Metro Manila and parts of Rizal Province.
The RTC lacked jurisdiction to review a final order of a quasi-judicial agency under Rule 43.

In CA-G.R. SP No. 119842, the CA initially ruled that the RTC lacked jurisdiction over the case and affirmed GAB’s authority to regulate jai alai activities outside the CSEZFP, thereby reversing the RTC’s injunctive orders and dismissing Meridien’s Complaint for Injunction.
Meridien then filed a Motion for Reconsideration, challenging especially the CA’s pronouncement on GAB’s authority.
With a 3-2 division, the CA partially granted Meridien’s motion in a Resolution dated September 11, 2012, clarifying that GAB’s regulatory authority did not extend within the CSEZFP—underscoring that within the CSEZFP, regulatory powers rest with CEZA.
GAB subsequently filed its own Motion for Reconsideration, contesting that the partial grant effectively revived the nullified injunctive orders, particularly within the CSEZFP. This motion was denied in a Resolution dated March 5, 2013.

Responding to a query from the Secretary of the Interior and Local Government (SILG) regarding the legality of off-fronton gaming operations, the Secretary of Justice (SOJ) issued DOJ Opinion No. 24.
The opinion held that under the CEZA license, Meridien was authorized to operate off-fronton betting stations only “if it is allowed by law,” and since RA No. 954 expressly prohibited such operations, Meridien could only legally operate within the premises of an enclosed fronton inside the CSEZFP.
In line with the DOJ and DILG’s oversight, Joint Memorandum Circular No. 001-2011 was issued, directing public officers to deny business permits for Meridien’s off-fronton operations, order the closure and seizure of equipment, and prosecute violators of RA No. 954.
Meridien further challenged the Joint Memorandum by filing a Petition for Certiorari and Prohibition in CA-G.R. SP No. 120236, which led the CA to issue a 60-day TRO and, subsequently, a WPI pending resolution of related issues.

The issues arising from the revocation of CEZA’s license, the litigations involving GAB’s CDO, the issuance of various TROs/WPIs, and the separate but related action challenging the DOJ-DILG joint directives culminated in two separate sets of petitions: G.R. No. 199972 (addressing the CA’s use of judicial courtesy and jurisdiction issues) and G.R. No. 206118 (focusing on GAB’s regulatory authority and the scope of its CDO).
Both sets of petitions generated extensive interlocutory rulings by the CA which were later brought before the Supreme Court for final resolution.

Whether the CA committed grave abuse of discretion in issuing a Writ of Preliminary Injunction (WPI) based primarily on judicial courtesy without a clear and unmistakable legal right supporting Meridien’s claim.
Whether the CA had jurisdiction to issue the WPI and to govern the resolution of the main case pending before the lower court.

Whether the CA erred in clarifying that the Cease-and-Desist Order (CDO) applies only to off-fronton operations.
Whether the CA erred in qualifying that the Games and Amusement Board (GAB) lacked regulatory authority inside the CSEZFP.

Whether the exercise of judicial courtesy is an appropriate ground for issuing injunctive relief where a clear legal right is absent.
The proper limits of judicial review under Rule 65 of the Revised Rules of Court in cases involving quasi-legislative actions and regulatory authority.