Case Digest (G.R. No. 86695) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Malaga et al. v. Penachos et al. (G.R. No. 86695, September 3, 1992), petitioners Maria Elena Malaga (doing business as B.E. Construction), Josieleen Najarro (doing business as Best Built Construction) and Jose N. Occena (doing business as Jose N. Occena Firm), together with Iloilo Builders Corporation, challenged the Pre-qualification, Bids and Awards Committee (PBAC) of the Iloilo State College of Fisheries (ISCOF) and its president, Benigno Panistante, for excluding them from a December 12, 1988 bidding on the ground that their documents were filed past a cut‐off time the PBAC had unilaterally advanced to 10:00 a.m. on December 2, 1988. Petitioners claimed they had complied with the published invitation to bid, which did not fix an hour for the pre‐qualification deadline, but were refused participation, thereby losing access to plans and specifications and missing the scheduled bidding. They secured a temporary restraining order from the Regional Trial Court of Iloilo, enj Case Digest (G.R. No. 86695) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Bidding Process and Petitioners’ Submissions
- The Iloilo State College of Fisheries (ISCOF), through its Pre-qualification, Bids and Awards Committee (PBAC), published an Invitation to Bid on November 25, 26 and 28, 1988 for the construction of a Micro Laboratory Building, setting December 2, 1988 as the deadline for submission of PRE-C1 documents and December 12, 1988 at 3:00 p.m. for bid opening.
- Petitioners Maria Elena Malaga and Josieleen Najarro filed their PRE-C1 at 2:00 p.m. on December 2; petitioner Jose N. Occena filed on December 5. All were excluded from bidding for missing a 10:00 a.m. cut-off on December 2, and were denied plans and specs necessary to prepare bids.
- Lower Court Proceedings
- On December 12, 1988 petitioners sought a TRO and preliminary injunction from the Regional Trial Court (RTC) of Iloilo to reset bidding, compel acceptance of PRE-C1, and enjoin award; the RTC issued a restraining order the same day.
- Defendants moved to lift the TRO, invoking P.D. 1818’s ban on injunctions in government infrastructure projects and mootness (TRO served after bid opening). On January 2, 1989 the RTC lifted the TRO and denied the preliminary injunction.
- Supreme Court Petition and Parties’ Contentions
- Petitioners contended ISCOF is a separate chartered institution not covered by P.D. 1818; they alleged bidding anomalies—undefined submission time, unilateral deadline changes without adequate notice, use of wrong Invitation to Bid form, late issuance of plans and specifications—and maintained the TRO remained effective until award.
- Private respondents argued ISCOF is a government instrumentality under P.D. 1818 (per its charter and Administrative Code); deadlines were duly posted; petitioners’ documents were late and their licenses expired; petitioners failed to challenge disqualification promptly; and plans were issued within the regulatory timeframe.
Issues:
- Is the prohibition of injunctions under P.D. 1818 applicable to ISCOF’s infrastructure project?
- Did the RTC err in issuing and then lifting the restraining order under P.D. 1818 and mootness grounds?
- Do the alleged PBAC bidding irregularities warrant injunctive relief despite P.D. 1818?
- What liabilities and remedies should be imposed on parties responsible for those anomalies?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)