G.R. No. L-17863 - Barredo vs. Court of Appeals

Republic Act No. 8479 (Downstream Oil Industry Deregulation Act of 1998) was enacted on February 10, 1998, aiming to liberalize and deregulate the downstream oil industry, ensuring a competitive market with fair prices, adequate supply, and high-quality petroleum products.
Section 14 of RA 8479 authorized the Department of Energy (DOE) to monitor and publish daily international crude oil prices and track domestic oil price movements.
Section 15 granted the DOE Secretary additional powers connected to enforcing RA 8479, including investigation and information-gathering mandates.
Following RA 8479, the DOE issued Department Circular No. DC2019-05-0008 (the Circular), setting Revised Guidelines for Monitoring Prices in the Sale of Petroleum Products, requiring oil companies to submit detailed price computations and supporting documents to the Oil Industry Management Bureau (OIMB).

On June 21, 2019, the Philippine Institute of Petroleum, Inc. (PIP), together with Isla LPG Corporation, PTT Philippines Corporation, and Total Philippines Corporation (collectively PIP et al.), filed a Petition for Declaratory Relief with Application for a Temporary Restraining Order (TRO) and Writ of Preliminary Injunction before the Regional Trial Court (RTC) of Makati City.
PIP et al. alleged that the Circular violated their rights and was contrary to RA 8479 for reasons including: it constituted price control conflicting with the policy of deregulation; it imposed impossible requirements; it lacked legal support; and it violated their rights to a competitive market and protection of trade secrets.
The RTC granted the TRO on June 28, 2019, enjoining DOE from enforcing the Circular for 20 days.
An amended petition was filed on July 12, 2019, followed by a hearing for the writ of preliminary injunction on July 15, 2019.

In its August 14, 2019 Resolution, the RTC granted PIP et al.'s application for a writ of preliminary injunction, enjoining the DOE from implementing the Circular pending resolution of the main petition, conditioned on a bond of PHP 500,000.
The DOE's motion for reconsideration was denied on December 3, 2019.

The DOE filed a Petition for Certiorari before the Court of Appeals (CA), contesting the RTC’s refusal to dismiss the case on grounds of forum shopping and litis pendentia and the issuance of the writ of preliminary injunction.
The CA, in its October 3, 2022 Decision, partially granted the DOE’s petition by reversing and setting aside the RTC’s order granting the writ of preliminary injunction but retained the order not dismissing the case for failure to prove forum shopping and litis pendentia.

PIP et al. filed a Petition for Review on Certiorari before the Supreme Court, assailing the CA’s reversal of the preliminary injunction but agreeing with the denial of dismissal of the case.

Whether the Court of Appeals erred in reversing and setting aside the Regional Trial Court’s issuance of the writ of preliminary injunction enjoining the DOE from implementing Department Circular No. DC2019-05-0008.