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 leading to the case began in 1985 when Libangang Malolos, Inc. sought to renew its license to operate the Malolos Cockpit Arena located in Sitio Canlapan, Barangay Sto. Rosario, Malolos, Bulacan, where it had been in operation since 1914. The Acting Mayor of Malolos denied the renewal based on Sangguniang Bayan Resolutions Nos. 6 and 9, which prohibited operations in the area. Following this denial, Libangang filed a complaint with the PGC on January 22, 1985, seeking a review of the Mayor's decision and permission to resume operations. The PGC granted Libangang the authority to resume operations on January 31, 1985. In response, the Municipality of Malolos filed a Petition for Certiorari and Prohibition with the Regional Trial Court (RTC) to restrain Libangang from ope...

Facts:

Background of the Case

• Private respondent, Libangang Malolos, Inc. (Libangang), has been operating the Malolos Cockpit Arena in Malolos, Bulacan, since 1914.
• Before the expiration of its license, Libangang sought its renewal for 1985, but the Acting Mayor of Malolos denied the renewal based on Sangguniang Bayan Resolutions Nos. 6 & 9, which disallowed its operation as it was within a prohibited area.

Filing of Complaint with the Philippine Gamefowl Commission (PGC)

• On January 22, 1985, Libangang filed a complaint with the PGC (Case No. 59) seeking a review of the Mayor's decision and requesting authority to resume operations pending the hearing.
• On January 31, 1985, the PGC issued a Resolution allowing Libangang to resume operations.

Petition for Certiorari and Prohibition

• On February 2, 1985, the Municipality of Malolos filed a Petition for Certiorari and Prohibition with the Regional Trial Court (RTC) of Malolos, Bulacan (Civil Case No. 7973-M), seeking to restrain the operation of the Malolos Cockpit Arena and to declare that the PGC had no jurisdiction to order its resumption.
• The PGC filed a Motion to Dismiss the case, arguing that the Court of Appeals had exclusive appellate jurisdiction over orders of quasi-judicial agencies like the PGC.

RTC and Court of Appeals Proceedings

• The RTC initially dismissed the case for lack of merit and jurisdiction, but upon reconsideration, Judge Felipe Villajuan, Jr., issued a Writ of Preliminary Injunction, restraining Libangang from operating the cockpit.
• The PGC and Libangang filed a Petition with the Court of Appeals to annul the RTC Orders.
• On January 12, 1987, the Court of Appeals reversed the RTC Orders, dissolved the Writ of Preliminary Injunction, and ruled that the RTC had no jurisdiction over the PGC and the subject matter of the case.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Jurisdiction: The Court emphasized that the PGC, as a quasi-judicial agency, is statutorily at par with the RTC. Therefore, the RTC cannot interfere with the PGC's orders, as this would violate the principle that a court cannot interfere with the judgments or decrees of a court of concurrent or coordinate jurisdiction.
2. Power of Review and Supervision vs. Control: The Court reiterated the ruling in Hee Acusar v. IAC (146 SCRA 294) that the PGC's power over municipal authorities is limited to review and supervision, not control. The PGC cannot substitute its discretion for that of municipal authorities in issuing licenses for ordinary cockpits. The power of review and supervision does not include the authority to annul or override the decisions of municipal officials.

Conclusion:

The Supreme Court affirmed the Court of Appeals' ruling on the issue of jurisdiction but reversed its decision on the extent of the PGC's authority. The Court held that the RTC has no jurisdiction over the PGC, and the PGC's power over municipal authorities is limited to review and supervision, not control.