G.R. No. 225141 - Energy Regulatory Commission vs. Vega, Jr.

The case originated from a petition for declaratory relief filed by Manila Electric Company (Meralco) before the Regional Trial Court (RTC), Branch 157, Pasig City, docketed as Special Civil Action No. 4149-PSG.
Meralco sought to have certain issuances by the Department of Energy (DOE) and the Energy Regulatory Commission (ERC) related to the Retail Competition and Open Access (RCOA) provision of the Electric Power Industry Reform Act of 2001 (EPIRA) declared null and void.
Alongside its main prayer for a declaration, Meralco included an ancillary prayer requesting the issuance of a Temporary Restraining Order (TRO) and/or a writ of preliminary injunction to enjoin the implementation of the disputed DOE/ERC issuances.

On June 13, 2016, the RTC granted Meralco’s prayer by issuing a 20-day TRO in favor of Meralco.
The issuance of the TRO was based on Meralco’s application for injunctive relief, as an ancillary relief to its petition for declaratory relief.
Subsequently, on July 13, 2016, the RTC issued a writ of preliminary injunction granting further relief to Meralco by enjoining the implementation of the DOE/ERC issuances.

The Energy Regulatory Commission (ERC), as petitioner, assailed the RTC’s orders—first the 20-day TRO and then the writ of preliminary injunction—through a petition before the Court.
The ERC argued that the RTC overstepped its jurisdiction by venturing into a subject matter reserved for the Supreme Court, particularly concerning the issuance of orders that in effect restrain the implementation of EPIRA.
The ERC further claimed a violation of its right to due process based on alleged defects in the notice and preparation for the hearing, as well as the RTC’s failure to consider all the arguments raised and its predisposition in rendering its decision.

The RTC’s jurisdiction over the petition for declaratory relief was recognized as proper under Section 1, Rule 63 of the Rules of Court, which specifically grants jurisdiction over such matters.
However, decisions involving the issuance of injunctive relief (such as TROs and preliminary injunctions) that may impede the implementation of national policies, like those provided under EPIRA, are subject to strict limitations and, in certain aspects, fall under the exclusive purview of the Supreme Court.
The legal question revolves around whether there existed an urgent necessity justifying the issuance of injunctive relief to restrain acts that are, by law, subject to national government directives.

Whether the RTC properly exercised its jurisdiction over Meralco’s petition for declaratory relief concerning the DOE/ERC issuances.
Whether the ROC’s jurisdiction is limited to declaratory relief and does not extend to granting injunctive relief that restrains the implementation of EPIRA.

Whether the issuance of a 20-day TRO and the subsequent writ of preliminary injunction by the RTC constitute an abuse of discretion.
Whether there was any urgent necessity or clear establishment of a right that warranted the issuance of such injunctive relief.

Whether the alleged violation of the ERC’s right to due process through defects in the notice and the insufficient time to prepare for the hearing justified the RTC’s issuance of the injunctive orders.
Whether the RTC’s actions prejudged the case and thereby compromised the proper course of adjudication.