Case Digest (G.R. No. 206808-09)
Facts:
Local Water Utilities Administration Employees Association for Progress (LEAP), et al. v. Local Water Utilities Administration (LWUA) and Department of Budget and Management, G.R. Nos. 206808-09, September 07, 2016, the Supreme Court Third Division, Peralta, J., writing for the Court.Petitioners are members/officers of LEAP and affected LWUA employees; respondents are LWUA and the Department of Budget and Management (DBM). The dispute arose from Executive Orders and an internal LWUA reorganization that produced a new staffing pattern and threatened the displacement or separation of some LWUA personnel.
In chronological order: President Gloria Macapagal-Arroyo issued E.O. No. 279 (Feb. 2, 2004) directing reforms in the water sector, E.O. No. 366 (Oct. 4, 2004) ordering strategic reviews and rationalization across the Executive Branch, and E.O. No. 421 (Apr. 13, 2005) specifically refocusing LWUA's functions and offering options/incentives for affected personnel. Pursuant thereto, LWUA formed Task Force 421 and an Action Team (which included petitioner Melanio Cuchapin II) to prepare a staffing pattern; the LWUA Board approved a 467-position pattern (Board Resolution No. 69, Apr. 18, 2006). The DBM approved 447 of those positions (Sept. 27, 2006). LWUA issued Office Order No. 168-06 (Oct. 18, 2006) to implement the DBM-approved staffing pattern and related implementation rules.
On October 19, 2006 petitioners filed a principal action for certiorari, prohibition and mandamus with prayer for TRO and preliminary injunction in the Regional Trial Court (RTC), Quezon City, Branch 92 (SP. Proc. No. Q-06-59047), alleging grave abuse of discretion by respondents and imminent dismissals of 233 LWUA employees. The RTC granted a writ of preliminary injunction on December 7, 2006, restraining respondents from enforcing the DBM-approved staffing pattern, Board Resolution No. 69, and E.O. Nos. 279, 366 and 421, subject to a P100,000 bond.
Respondents moved for reconsideration before the RTC; the RTC denied the motions in a June 6, 2007 Resolution. LWUA and DBM then filed separate special civil actions for certiorari with the Court of Appeals (CA), which were consolidated as CA-G.R. SP Nos. 100482 and 100662. On August 28, 2012 the CA reversed the RTC, set aside the preliminary injunction, and on January 15, 2013 denied petitioners' motion for reconsideration. Meanwhile, on December 27, 2012 the RTC dismissed petitioners' principal action for lack of a justiciable controversy and as the wrong remedy.
Petitioners then filed a petition for certiorari under Rule 65 w...(Subscriber-Only)
Issues:
- Was a petition for certiorari under Rule 65 the proper remedy to assail the Court of Appeals’ Decision and Resolution?
- Does a writ of preliminary injunction issued by the trial court survive the dismissal of the principal action that it ancillary supports?
- Were petitioners required to exhaust administrative remedies under R.A. No. 6656 (and submit to the primary jurisdiction of administrative bodi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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