Facts:

• The case involves a petition for review on certiorari filed by the Executive Secretary, the Secretary of Justice, the Secretary of Labor and Employment, the Secretary of Foreign Affairs, the POEA Administrator, and the OWWA Administrator (petitioners).
• The respondents are the Court of Appeals and the Asian Recruitment Council Philippine Chapter, Inc. (ARCO-Phil.), representing its members, which include several licensed recruitment agencies.
• The case arose from the enactment of Republic Act No. 8042, known as the Migrant Workers and Overseas Filipinos Act of 1995, effective July 15, 1995.
• ARCO-Phil. filed a petition for declaratory relief with the Regional Trial Court (RTC) of Quezon City on July 17, 1995, challenging the constitutionality of several provisions of the law.
• ARCO-Phil. sought a temporary restraining order and/or writ of preliminary injunction to prevent the enforcement of these provisions.
• The RTC issued a temporary restraining order on August 1, 1995, and later granted a writ of preliminary injunction on August 24, 1995.
• The petitioners challenged this decision in the Court of Appeals, which affirmed the RTC's order.
• The petitioners then brought the case to the Supreme Court, arguing that the RTC committed grave abuse of discretion and that ARCO-Phil. lacked standing to file the petition.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court ruled that the trial court committed grave abuse of discretion in issuing the writ of preliminary injunction.
2. The Supreme Court held that ARCO-Phil. has the legal standing to file the petition on behalf of i...(Unlock)

Ratio:

1. Grave Abuse of Discretion:

   • The Supreme Court found that the RTC's issuance of the writ of preliminary injunction was not supported by sufficient evidence of irreparable injury to ARCO-Phil.'s members.
   • The law is presumed constitutional until declared otherwise by a final judgment.
   • The penal provisions of Republic Act No. 8042 had been applied in various cases, and enforcement could not be enjoined based on mere conjectures or speculations.
   • The public interest in prosecuting illegal recruiters and protecting overseas Filipino workers was not adequately considered by the trial court.

2. Locus Standi:

   • An association like ARCO-Phil. has standing to file a suit on behalf of its members if its members are affected by the action.
   • ARCO-Phil. had a substantial relation to its members, who are licensed and registered recruitment agencies, and had been expressly authorized b...continue reading