Case Digest (G.R. No. L-59234)
Facts:
The case involves the Municipality of Malolos as the petitioner and Libangang Malolos, Inc., represented by Ceferino Tiongson, along with the Philippine Gamefowl Commission (PGC) as respondents. The events in question trace back to the year 1985 when Libangang had been operating the "Malolos Cockpit Arena" in Sitio Canlapan, Barangay Sto. Rosario, Malolos, Bulacan since 1914. Prior to the expiration of its operating license, Libangang sought a renewal for the year 1985, which was denied by the Acting Mayor of Malolos. The denial was based on Sangguniang Bayan Resolutions Nos. 6 and 9 that prohibited cockpit operations in that area. As a result of the non-renewal, Libangang filed a complaint with the PGC on January 22, 1985, challenging the Mayor's action, which was docketed as Case No. 59. The complaint requested the authority to resume operations pending the resolution of the issue. The PGC subsequently granted permission for Libangang to resume operations on Jan
Case Digest (G.R. No. L-59234)
Facts:
- Parties Involved
- Petitioner: Municipality of Malolos, which initiated the petition for review on certiorari.
- Respondents:
- Libangang Malolos, Inc., a private entity operating the Malolos Cockpit Arena since 1914.
- Philippine Gamefowl Commission (PGC), represented by Ceferino Tiongson, the quasi-judicial agency involved in the licensing dispute.
- Operational Background and License Renewal Dispute
- Libangang Malolos, Inc. had been operating the Malolos Cockpit Arena at sitio Canlapan, Barangay Sto. Rosario, Malolos, Bulacan since 1914.
- Prior to the expiration of its license, Libangang sought renewal for 1985.
- The Acting Mayor of Malolos denied the renewal based on Sangguniang Bayan Resolutions Nos. 6 & 9, which disallowed the operation within a prohibited area.
- Initiation of Legal Proceedings by Libangang
- On January 22, 1985, Libangang filed a complaint with the PGC (docketed as Case No. 59, “Malolos Libangang Cockpit vs. Municipal Mayor of Malolos”) challenging the Mayor’s action and seeking a review of the decision.
- Libangang also requested authority to resume cockpit operations pending the hearing on the merits.
- The PGC granted this request via a Resolution dated January 31, 1985, thereby allowing resumed operations.
- Municipality’s Counteraction and Injunction Case
- On February 2, 1985, the Municipality of Malolos filed a Petition for Certiorari and Prohibition with the Regional Trial Court (RTC), Branch XV (Civil Case No. 7973-M).
- The petition sought to restrain and enjoin Libangang’s operation of the cockpit arena.
- It also sought a declaration that the PGC lacked jurisdiction to order the resumption of operations.
- On February 22, 1985, the PGC moved to dismiss the Injunction Case asserting that under Section 9(3) of Batas Pambansa Blg. 129, appeal jurisdiction over orders of quasi-judicial agencies is exclusive to the Court of Appeals.
- The RTC initially dismissed the case on August 20, 1985, through an order by Judge Manuel E. Yuzon for lack of merit and jurisdiction.
- Reconsideration and Subsequent RTC Orders
- Following a Motion for Reconsideration by the Municipality, RTC Judge Felipe Villajuan, Jr. set aside the previous order.
- On January 28, 1986, he granted reconsideration and issued a new order.
- On February 5, 1986, he amended the order motu proprio by issuing a Writ of Preliminary Injunction directing Libangang to suspend its operations pending trial.
- Appeal to the Court of Appeals and Decision
- On September 23, 1986, the PGC and Libangang jointly filed a petition with the Court of Appeals to annul the RTC orders.
- On January 12, 1987, the Court of Appeals rendered a decision that:
- Reversed the RTC order issuing the writ of preliminary injunction, effectively dissolving it.
- Held that the RTC lacked jurisdiction over the matter, particularly the review of PGC’s orders, given the exclusive appellate jurisdiction provided under BP Blg. 129 and related rules.
- A motion to reconsider the Court of Appeals’ decision was denied, notably emphasizing jurisdictional boundaries due to the pending PGC case (Case No. 59).
- Core Controversial Issues Identified
- Whether the RTC had jurisdiction to review orders issued by the PGC concerning the resumption of Libangang’s operations.
- Whether the authority of municipal mayors to issue licenses to operate cockpits is subject to review and supervision – or even control – by the Philippine Gamefowl Commission.
Issues:
- Jurisdictional Competence of the Regional Trial Court
- Is the RTC empowered to review and restrain orders issued by a quasi-judicial agency such as the Philippine Gamefowl Commission?
- Does the statutory provision under BP Blg. 129 and corresponding rules confer exclusive appellate review of such decisions to the Court of Appeals?
- Extent of Municipal Authority in Licensing
- Can the municipal mayor, with the concurrence of the Sangguniang Bayan, exercise primary authority to license and regulate ordinary cockpits?
- Is the municipal mayor’s power subject to the control or overriding supervision of the PGC, or is the Commission’s function merely limited to review and supervision?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)