G.R. No. 100874 - Espiritu vs. Melgar

The case involves a special civil action for certiorari and prohibition initiated by Governor Benjamin I. Espiritu against Judge Marcianno T. Virola of the Regional Trial Court of Oriental Mindoro and other respondents.
The controversy centers on whether the RTC judge had jurisdiction to issue a writ of preliminary injunction that restrained the Governor from implementing an order of preventive suspension against Mayor Nelson B. Melgar.

On March 26, 1991, an incident occurred in Naujan, Oriental Mindoro, during the graduation ceremonies at the Jose L. Basa Memorial School.

Ramir Garing, in attendance, initiated a recurring bout of loud clapping which disrupted the proceedings.
Mayor Melgar, while delivering his speech, paused and eventually ended his address due to the disturbance.

Subsequently, Ramir Garing filed a sworn complaint on April 11, 1991, with the Department of Interior and Local Government, alleging that Mayor Melgar had engaged in grave misconduct, oppression, abuse of authority, and culpable violation of the Constitution.

The specific allegation stated that on the said date, the mayor attacked Garing, inflicting physical injuries, and ordered his arrest and detention without formally filing charges.

An identical complaint was submitted to the Provincial Governor, Benjamin I. Espiritu, with a request for preventive suspension pending investigation.
A third complaint was forwarded by the Presidential Action Center, calling for prompt action.

The Sangguniang Panlalawigan of Oriental Mindoro received the complaints and required Mayor Melgar to answer them.

On May 22, 1991, Mayor Melgar submitted an answer recounting the events of March 26, 1991, detailing his version of the incident and justifying his actions.
His answer included affidavits from various witnesses such as teachers, a municipal jailer, a police investigator, and a fireman.

The Sangguniang Panlalawigan docketed the case under Adm. Case No. 91-01.
On May 9, 1991, Resolution No. 55 was passed, recommending the preventive suspension of Mayor Melgar for 45 days pending investigation.
On May 28, 1991, Governor Espiritu acted on this recommendation and placed Mayor Melgar under preventive suspension based on findings corroborated by witness affidavits.

Mayor Melgar, contesting his suspension, filed a petition for certiorari with a preliminary injunction in the RTC of Oriental Mindoro (Special Civil Action No. R-5003).

He argued that the suspension was an arbitrary and abusive exercise of power by the Governor.

On June 24, 1991, RTC Judge Virola issued a writ of preliminary injunction against Governor Espiritu, effectively stopping the implementation of the order of suspension.

The judge based his decision on the credibility of the affidavits in the administrative case, favoring the respondent mayor’s account over that of the complainant.

Governor Espiritu subsequently filed a motion to dismiss and/or for reconsideration, which was denied on July 16, 1991, by Judge Virola.
Further developments included the court’s issuance of a Temporary Restraining Order directing the respondent Judge to halt proceedings in Special Civil Action No. R-5003, and Mayor Melgar’s later unsuccessful motion to lift the TRO on August 22, 1991.
Eventually, the petition for certiorari and prohibition was brought before the Supreme Court, challenging both the RTC’s issuance of the writ and its denial of the motion to dismiss.

Whether the Regional Trial Court had jurisdiction over the special civil action involving an administrative matter, specifically the preventive suspension order imposed by the Governor under the Local Government Code.

Whether the issuance of the writ of preliminary injunction by RTC Judge Virola constituted a grave abuse of discretion and an impermissible encroachment on executive functions.
Whether the RTC properly exercised its discretion in refusing to dismiss Special Civil Action No. R-5003, given that preventive suspension decisions are within the purview of administrative bodies.

Whether Mayor Melgar’s direct recourse to the courts, rather than exhausting all available administrative remedies (e.g., seeking relief at the Department of the Interior and Local Government), was premature and procedurally improper.