Case Digest (G.R. No. 157498)
Facts:
Filipino Metals Corporation et al. v. Secretary of the Department of Trade and Industry, G.R. No. 157498, July 15, 2005, Supreme Court First Division, Quisumbing, J., writing for the Court. Petitioners are a group of domestic steel manufacturers (listed collectively) who rely heavily on imported steel billets as principal raw materials; domestic suppliers meet only about 15% of national demand and produce lower-quality billets from scrap. Respondents are the Secretary of the Department of Trade and Industry, the Secretary of the Department of Agriculture, the Secretary of the Department of Finance, the Commissioner of the Bureau of Customs, and the Chairman of the Tariff Commission.On July 17, 2000, Republic Act No. 8800 (the Safeguard Measures Act), which implements Article XIX of GATT and the WTO Agreement on Safeguards, was enacted authorizing safeguard measures against import surges. On April 6, 2001, petitioners filed in the Regional Trial Court (RTC) of Valenzuela City, Branch 172, a petition for declaratory relief and/or certiorari and prohibition seeking a declaration that R.A. 8800 is unconstitutional and, in the meantime, injunctive relief against its enforcement. The RTC, while holding the constitutional question in abeyance, found petitioners had made a strong showing against the law’s validity and, upon posting of a P10,000,000 bond, issued a writ of preliminary injunction on September 4, 2001 restraining respondents from enforcing R.A. 8800 and its implementing rules.
Respondents petitioned the Court of Appeals (CA) for certiorari; the CA, in CA-G.R. SP No. 67397, dated February 28, 2003, held that the RTC committed grave abuse of discretion in issuing the injunction, reversed the RTC order, and dissolved the injunction on the ground that petitioners had not rebutted the presumption of constitutionality and had not shown a clear legal right warranting injunctive relief. Petitioners then filed a petition for review on certiorari with this Court contesting the CA’s reversal and raising ancillary issues including whether the WTO agreement argument was properly raised and whether respondents engaged in forum-shopping.
This Court treated the matter as a petition for review on certiorari (Rule 45) an...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in reversing the Regional Trial Court’s issuance of a writ of preliminary injunction restraining enforcement of R.A. 8800?
- Was the contention that R.A. 8800 impairs Philippine treaty obligations under the WTO Agreement on Safeguards properly considered at the trial-court level for purposes of enjoining the law?
- Have petitioners adequately shown a clear right to injunctive relief under Rule 58, Section 3 of the Revised Rules of Court?
- Did the Court of Appeals commit reversible error by failing to dismiss the third petitio...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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