G.R. No. 94759 - Technology Developers, Inc. vs. Court of Appeals

Petitioner Technology Developers, Inc. is a domestic private corporation engaged in the manufacture and export of charcoal briquettes located in Guyong, Sta. Maria, Bulacan.
Private respondent Hon. Vicente Cruz was the Acting Mayor of Sta. Maria, Bulacan. The respondent judge refers to the presiding judge of the Bulacan Regional Trial Court (RTC).

On February 16, 1989, the Acting Mayor issued a letter ordering the full cessation of operations of petitioner’s plant until further notice. The letter requested the production of:

Building permit
Mayor’s permit
Region III - Department of Environment and Natural Resources Anti-Pollution permit
Other related documents

Petitioner agreed to comply and started to secure the Environmental Management Bureau’s Anti-Pollution Permit (successor to the National Pollution Control Commission permit).
Petitioner was informed it lacked a Mayor’s permit. Attempts to secure the Mayor's permit were unsuccessful; the Mayor’s office refused to entertain petitioner’s representatives.

On April 6, 1989, acting without prior reasonable notice to petitioner, the Acting Mayor ordered the Municipal police to padlock the petitioner’s plant, effectively ceasing its operations.
Petitioner filed an action for certiorari, prohibition, and mandamus with a prayer for a writ of preliminary mandatory injunction, alleging grave abuse of discretion in the closure order.
On April 19, 1989, the RTC granted preliminary mandatory injunction, ordering the revocation of the plant’s closure upon petitioner’s posting of a P50,000 bond. The injunction was issued on April 28, 1989.

The Acting Mayor filed a motion for reconsideration on May 3, 1989, heard May 30, 1989, without petitioner’s counsel present.
Evidence submitted included:

Investigation report (Exhibit “A”) detailing hazardous fumes affecting community health, recommending cessation of operations until appropriate air pollution controls are installed.
Petitions and complaints (Exhibits “B”, “B-1”, “B-2”, “B-3”) from local residents and a letter to the Provincial Governor about the smoke pollution.

On June 14, 1989, the RTC set aside the preliminary injunction and dissolved the writ.
Petitioner’s motion for reconsideration was denied on August 9, 1989.

Petitioner appealed to the Court of Appeals, which denied the petition for certiorari and prohibition with preliminary injunction on January 26, 1990, and also denied the motion for reconsideration on August 10, 1990.
The petitioner then filed a petition for review on certiorari before the Supreme Court.

Whether the Court of Appeals committed grave abuse of discretion in affirming the trial court’s order that dissolved the writ of preliminary mandatory injunction enjoining the closure of petitioner’s plant.

Whether the Acting Mayor acted within his police powers in ordering the cessation and closure of petitioner’s plant without prior and reasonable notice, given the environmental and health concerns raised.

Whether petitioner’s failure to secure a valid Mayor’s permit and valid anti-pollution permits justified the closure of the plant.