Title
Urbanes, Jr. vs. Court of Appeals
Case
G.R. No. 117964
Decision Date
Mar 28, 2001
A security agency disputes bidding irregularities in a contract with SSS, leading to legal battles over injunctions, jurisdictional issues, and a Supreme Court remand.
security agency
government institution
contract
A

Case Digest (G.R. No. 117964)

Facts:

  • Parties and their roles
    • Petitioner Placido O. Urbanes, Jr. owned and operated Catalina Security Agency (CATALINA).
    • Respondent Social Security System (SSS) acted as the contracting government entity for security services.
    • The individual respondents were the Chairman and members of the SSS Purchase and Bidding Committee, namely Hector B. Inductivo, as Chairman; Godofredo S. Sison; Isabelo I. Liscano; Aurora E.L. Ortega; Susana K. Inciong; Edgar B. Solilapsi; and Cecilia C. Canlas.
  • First security contract and earlier bidding controversies
    • In 1987, CATALINA was first awarded a contract to provide security services to the SSS through a public bidding.
    • The contract covered July 1, 1988 to June 30, 1989.
    • The contract was then extended on a month-to-month basis until another public bidding was held on August 16, 1990.
    • CATALINA participated as a bidder in the August 16, 1990 public bidding.
    • The contract was awarded to Bolinao Security and Investigation Services.
  • First action for injunctive relief and appellate proceedings
    • Alleging irregularities and anomalies in the public bidding, CATALINA filed Civil Case No. Q-91-7798 before the Regional Trial Court of Quezon City.
    • CATALINA prayed for an injunction to enjoin the award of the security services contract to Bolinao Security and Investigation Services.
    • The trial court issued a writ of preliminary injunction restraining the SSS from awarding the contract to Bolinao.
    • The SSS filed a petition for certiorari before the Court of Appeals, docketed as CA-G.R. SP No. 26633, to annul the writ of preliminary injunction.
    • The Court of Appeals dismissed the petition for failure of the SSS to attach certified true copies of the assailed orders of the trial court and failure to state certain material data.
    • The SSS moved for reconsideration, but the Court of Appeals denied it.
    • The SSS then filed a second petition for certiorari to nullify the questioned orders of the trial court.
    • The Court of Appeals dismissed the second petition in a decision dated October 30, 1992.
  • Compromise agreement and its effect
    • A compromise agreement was forged between respondent Urbanes of CATALINA and the SSS.
    • The trial court rendered a decision approving the compromise agreement.
    • The compromise agreement provided:
1) Each party mutually agreed to withdraw its claim for damages against the other. 2) The SSS would conduct a new public bidding, with CATALINA already considered a qualified participant. 3) In the meantime, CATALINA would continue to provide security services to the SSS until a new public bidding was actually conducted and a valid award was made.
  • New public bidding, award, and subsequent dispute
    • Pursuant to the compromise agreement, the SSS conducted a new public bidding with CATALINA as a qualified participant.
    • The Social Security Commission awarded the contract to Jaguar Security and Investigation Services, Inc. (JAGUAR).
    • The contract for security services was executed on May 12, 1994, between the Social Security Commission and JAGUAR.
    • The following day, a formal notice was sent to CATALINA for it to turn over the security services to JAGUAR.
    • CATALINA believed there was fraud and arbitrariness in the evaluation of the bids.
  • Second action for damages and injunction; interim orders of the trial court
    • CATALINA filed an action for damages and injunction, with application for a temporary restraining order, before the Regional Trial Court of Quezon City.
    • CATALINA prayed:
1) To prevent, restrain, and enjoin the SSS from terminating CATALINA’s services. 2) To annul the award made in favor of JAGUAR. 3) For awards of penal and exemplary damages.
  • On May 13, 1994, the trial court issued a temporary restraining order.
  • After due hearing, the trial court granted a preliminary injunction with a P100,000.00 bond, enjoining and restraining the respondents, including the Purchase and Bidding Committee members, from:
1) Terminating CATALINA’s services; and 2) Proceeding with the award of the security contract in favor of JAGUAR or any other party
  • until the propriety of a permanent injunction would be determined.
  • On June 1, 1994, the trial court issued the writ of preliminary injunction enforcing the cessation of:
1) Terminating CATALINA’s services; and 2) Proceeding with the award of the contract to JAGUAR or any other party.
  • Court of Appeals certiorari proceedings and the assailed outcomes
    • On June 14, 1994, the SSS and the members of the Purchase and Bidding Committee filed a petition for certiorari before the Court of Appeals, docketed as CA-G.R. SP No. 34345.
    • The petition sought issuance of a writ of preliminary injunction and/or a temporary restraining order to enjoin enforcement of the trial court orders dated May 13 and May 31, 1994, and the writ of preliminary injunction dated June 1, 1994.
    • The private respondents also prayed for restraint against petitioner from proceeding with Civil Case No. Q-94-20557.
    • The private respondents cited the following grounds:
1) The trial judge allegedly ignored evidence that the SSS bidding was legal and fair, and that CATALINA’s bid was not advantageous to the SSS. 2) The trial judge allegedly disregarded the presumption of regularity of the public bidding. 3) The trial judge allegedly disregarded the SSS right to reject any or all bids. 4) CATALINA allegedly had no clear legal right threatened and requiring injunctive protection. 5) There allegedly was no irre...(Subscriber-Only)

Issues:

  • Jurisdiction of the Court of Appeals in certiorari against an interlocutory order
    • Whether the Court of Appeals exceeded its jurisdiction by dismissing the main action for damages and injunction pending before the trial court in Civil Case No. Q-94-20557.
    • Whether the Court of Appeals exceeded its jurisdiction by reviewing the lower court’s findings of fact, allegedly beyond the proper scope of certiorari review of the issuance of a writ of preliminary injunction.
  • Scope of review in certiorari vs. errors of judgment and factual findings
    • Whether certiorari proceedings assailing an interlocutory order could be used to finally determine the merits of a main case still awaiting trial.
    • Whether the Court of Appeals improperly delved into the facts and merits of the main case despite the rule that certiorari cannot correct erroneous conclusions of fact or law.
  • Propriety of the issuance of the writ of preliminary injunction...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)
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