Case Digest (G.R. No. 78592)
Facts:
Municipality of Malolos v. Libangang Malolos, Inc., G.R. No. 78592, April 08, 1988, Supreme Court Second Division, Melencio‑Herrera, J., writing for the Court. The petition contests a Court of Appeals decision in CA‑G.R. SP No. 09686 entitled “Philippine Gamefowl Commission, et al., vs. Hon. Felipe N. Villajuan, Jr., et al.,” which held that the Regional Trial Court lacked jurisdiction over the dispute and that municipal authority to issue cockpit licenses is subject to the supervision of the Philippine Gamefowl Commission (PGC).Libangang Malolos, Inc. (Libangang) had operated the Malolos Cockpit Arena in Bulacan since 1914. Before its license expired, Libangang applied for renewal for 1985, but the Acting Mayor of Malolos denied renewal based on Sangguniang Bayan Resolutions Nos. 6 and 9, which declared the operation disallowed as within a prohibited area.
Pursuant to Section 4 of P.D. No. 1802‑A, Libangang filed with the PGC a complaint on January 22, 1985 (Case No. 59), seeking review of the Mayor’s action and authority to resume operations pending resolution. On January 31, 1985 the PGC issued a resolution allowing Libangang to resume operations.
On February 2, 1985 the Municipality of Malolos filed a Petition for Certiorari and Prohibition in the Regional Trial Court (Branch XV, Malolos; Civil Case No. 7973‑M) to enjoin Libangang’s operation and to declare that the PGC had no jurisdiction to order resumption. The PGC moved to dismiss on February 22, 1985, invoking Section 9(3) of B.P. Blg. 129 (intermediate appellate jurisdiction over quasi‑judicial agencies). On August 20, 1985 Judge Manuel E. Yuzon dismissed the RTC action for lack of merit and want of jurisdiction.
The Municipality sought reconsideration; Judge Felipe N. Villajuan, Jr. granted it in an order dated January 28, 1986 (amended February 5, 1986), setting aside the prior dismissal, issuing a writ of preliminary injunction, and directing Libangang to cease operations pending trial. On September 23, 1986 the PGC and Libangang filed with the Court of Appeals a petition to annul Judge Villajuan’s orders.
On January 12, 1987 the Court of Appeals reversed Judge Villajuan, dissolved the writ, and held that the RTC lacked jurisdiction because the PGC had earlier assumed jurisdic...(Subscriber-Only)
Issues:
- Did the Regional Trial Court have jurisdiction to review the PGC’s orders and to enjoin the parties, or was jurisdiction vested in the Court of Appeals under B.P. Blg. 129 and related rules?
- Is the municipal mayor’s authority to grant licenses to operate ordinary cockpits subject to review and supervision by the Philippine Gamefowl Commission in a manner that allows the PGC to substitute its discretion...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)