G.R. No. 249434 - Jose vs. Quesada-Jose

The dispute centers on the Barangay Health Stations Project, an initiative designed to provide quality health care to the poor by establishing a functional Barangay Health Station in every barangay using public elementary schools as sites.
JBROS Construction Corporation entered into two separate contracts with the Department of Health (DOH) under Republic Act No. 9184 (Government Procurement Reform Act):

The first contract, executed on January 22, 2016, pertained to Phase I of the project and subsequently became the subject of an arbitration case.
The second contract, concerning Phase II, was executed in March 2016, with the understanding that DOH would deliver possession of all 2,500 sites by March 30, 2016.

JBROS contended that the completion of Phase II was conditioned upon DOH delivering the identified school sites.
In a letter dated May 16, 2016, JBROS alerted then DOH Secretary Janette Garin of delays, attributing them to miscommunication and lack of coordination with Regional Directors, thereby impeding the commencement of work.
DOH suspended the second contract on May 31, 2016, despite JBROS claiming progress amounting to 14.37% of the works.

Due to the suspension lasting nearly three years, JBROS sent a Notice of Termination on January 25, 2019, pursuant to R.A. No. 9184, which automatically terminated the contract on February 24, 2019 for failure on DOH’s part to resolve the issues.
Unexpectedly, JBROS received a Notice of Termination from DOH on March 1, 2019, accompanied by a verified report alleging irregularities on its part relating to Phase II.
Subsequent documents included an Amended Notice of Termination (April 4, 2019) and JBROS’s counterclaim insisting that the termination was due solely to DOH’s failure to perform.
On May 20, 2019, DOH formally declared the contract terminated, blacklisted JBROS, and demanded the return of a mobilization fee totaling approximately P551,233,333.33.
A motion for reconsideration regarding the DOH decision was denied in a resolution on July 15, 2019, and the formal Blacklisting Order was issued on July 24, 2019.
The Government Procurement Policy Board (GPPB) confirmed JBROS’s inclusion in the blacklist on August 30, 2019.

JBROS challenged the blacklisting order by filing a Petition for Certiorari with applications for a Temporary Restraining Order (TRO) or Status Quo Ante and a Writ of Preliminary Injunction.
The petition was first raffled to RTC Manila, Branch 12 (Civil Case No. 19-09240-SC) where Presiding Judge Renato Z. Enciso denied the issuance of the writ on September 26, 2019, holding that the acts complained of had already been completed.
JBROS later withdrew the case and then refiled a similar petition as a "Petition for Interim Measure of Protection in Aid of Arbitration" under R.A. No. 9285, urging an ex parte issuance of a 20-day Temporary Restraining Order of Protection, which was handled by RTC Manila, Branch 27 (Special Proceeding Case No. R-MNL-19-12843-SP).
On December 19, 2019, Judge Lily Joy LabayoAPatria of Branch 27 issued the 20-day TRO, which was followed by Judge Teresa Patrimonio-Soriaso’s issuance, on January 20, 2020, of a writ of preliminary injunction directing DOH to desist from implementing the termination, recall the blacklisting order, and submit a Delisting Order to the GPPB.

The controversy was brought to the attention of the Supreme Court through a letter dated March 9, 2020, from DOH Secretary Francisco T. Duque III, directed to Chief Justice Diosdado M. Peralta.
The Court referred the matter to the Office of the Court Administrator (OCA) for an investigation, report, and recommendation.
The OCA’s findings focused on two major issues:

The issuance of a writ of preliminary injunction in a case previously resolved by Judge Enciso, thereby creating a conflict between judicial decisions and undermining the doctrine of judicial stability.
The observation that JBROS had engaged in forum shopping by dismissing its earlier case before Judge Enciso to pursue a more favorable outcome in Branch 27.

Based on these findings, the OCA recommended holding Judge Soriaso administratively liable, including recommending a fine for both gross ignorance of the law/procedure and for violating Supreme Court rules and directives regarding injunctions.

Whether Judge Soriaso’s issuance of a writ of preliminary injunction was proper, particularly when the acts it sought to restrain had already been executed.
Whether the writ interfered with the earlier decision of Judge Enciso, thereby contravening the doctrine of judicial stability.

Determining if JBROS’ filing of two substantially similar cases in different RTC branches amounts to forum shopping.
Evaluating whether the alleged forum shopping affected the outcome, given that both cases sought the same relief against the DOH’s blacklisting order.

Whether Judge Soriaso displayed gross ignorance of the law and procedure by disregarding the earlier ruling and by issuing a contradictory injunction.
Determining the appropriate administrative sanction on a judge who, by presiding over these cases, potentially undermined judicial consistency and public confidence.

Whether Judge Soriaso’s actions were in conformity with Administrative Circular No. 7-99, including the proper issuance of temporary restraining orders and injunctions.
How the judge’s failure to heed these guidelines affected the legal and administrative stability of the proceedings.