Case Digest (G.R. No. 83558) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In National Power Corporation (NPC) v. Hon. Abraham P. Vera and Sea Lion International Port, Terminal Services, Inc., NPC, created under Republic Act No. 6395, as amended, operates the Batangas Coal-Fired Thermal Power Plant in Calaca, Batangas. Private respondent held an expired contract and permit for stevedoring and arrastre services at NPC’s pier and filed a complaint for prohibition and mandamus with damages against NPC and the Philippine Ports Authority (PPA), alleging bad faith and grave abuse of discretion in non-renewal of its contract. The Regional Trial Court (RTC), Branch 90, Quezon City, issued a restraining order, later converted into a writ of preliminary injunction dated June 8, 1988, enjoining NPC from performing stevedoring services at its own pier and directing NPC either to enter into a contract with private respondent or to conduct public bidding for those services. NPC filed an “Urgent Motion” to dissolve the injunction, arguing lack of jurisdiction under P Case Digest (G.R. No. 83558) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Contract
- National Power Corporation (NPC), a government-owned and controlled corporation created under Republic Act No. 6395, as amended, to generate and distribute electric power.
- Sea Lion International Port, Terminal Services, Inc. (Sea Lion), which previously held a Contract for Stevedoring Services for coal‐handling operations at NPC’s pier in Calaca, Batangas; the contract and its Philippine Ports Authority (PPA) permit expired before the events below.
- Proceedings Below
- Sea Lion filed a complaint for prohibition and mandamus with damages against NPC and the PPA before the Regional Trial Court (RTC), Branch 90, Quezon City, alleging bad faith and grave abuse of discretion in NPC’s refusal to renew its contract and in taking over stevedoring services.
- The RTC issued (a) a restraining order barring NPC from further stevedoring and arrastre services at its pier; (b) on June 8, 1988, a writ of preliminary injunction enjoining NPC from those services and directing it to either contract with Sea Lion or conduct public bidding; and (c) allowed Sea Lion to continue its operations.
- NPC filed a petition for certiorari with the Supreme Court, arguing that (a) under Presidential Decree No. 1818 the RTC lacked jurisdiction to issue injunctions against public utilities; and (b) Sea Lion had no cause of action for a preliminary injunction. The Supreme Court issued a temporary restraining order on June 15, 1988.
Issues:
- Jurisdiction
- Whether the RTC had jurisdiction under PD No. 1818 to issue a writ of preliminary injunction restraining NPC’s stevedoring operations.
- Corporate Power
- Whether NPC’s charter (RA No. 6395, as amended) empowers it to undertake stevedoring and arrastre services at its pier.
- Right to Injunction
- Whether Sea Lion established a clear legal right and cause of action warranting a preliminary injunction.
- Mandamus vs. Discretion
- Whether the RTC’s order improperly acted as a writ of mandamus compelling NPC’s corporate prerogative.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)