G.R. No. 117964 - Urbanes, Jr. vs. Court of Appeals

The petitioner, Placido O. Urbanes, Jr., owner and operator of Catalina Security Agency (CATALINA), initially secured a contract with the Social Security System (SSS) through a public bidding in 1987 for security services covering July 1, 1988 to June 30, 1989.
Following the initial contract, services were extended on a month-to-month basis until a new public bidding was held on August 16, 1990, wherein CATALINA was one of the bidders but the contract was awarded to Bolinao Security and Investigation Services.

CATALINA questioned the conduct of the public bidding, alleging irregularities and anomalies, and subsequently filed an action for injunction (Civil Case No. Q-91-7798) before the Regional Trial Court (RTC) of Quezon City to enjoin the contract award to Bolinao Security.
The RTC issued a writ of preliminary injunction restraining the SSS from awarding the said contract, prompting the SSS to petition the Court of Appeals (CA) for certiorari, which was dismissed for procedural defects and failure to state material data.
A motion for reconsideration by the SSS was denied, and a second petition for certiorari for the nullification of the RTC orders was also dismissed by the CA in October 1992.

Both parties agreed to withdraw their respective claims for damages.
SSS agreed to conduct a new public bidding, with CATALINA recognized as a qualified participant.
CATALINA was allowed to continue providing security services until a valid award resulted from the new bidding.

SSS subsequently conducted the bidding, and the contract was awarded to Jaguar Security and Investigation Services, Inc. (JAGUAR) with the contract executed on May 12, 1994.

On receiving a formal notice to hand over security services to JAGUAR on May 13, 1994, CATALINA alleged fraud and arbitrariness in the evaluation process and initiated another action for damages and injunction before the RTC.
CATALINA’s reliefs included:

A temporary restraining order to prevent termination of its services by the SSS.
A preliminary injunction to annul the award in favor of JAGUAR and to halt further processing of the award pending determination on the merits.

The RTC granted the application by issuing an order enjoining the SSS and its representatives from terminating CATALINA’s services and proceeding with the contract award.

On June 14, 1994, SSS along with its Purchase and Bidding Committee (PBAC) filed a petition for certiorari before the CA seeking:

Issuance of a writ of preliminary injunction or temporary restraining order to block the enforcement of the RTC orders and writ of preliminary injunction dated June 1, 1994.
An order restraining CATALINA from pursuing its separate action pending before the RTC.

The legal presumption of regularity in public bidding processes.
Contentions that CATALINA lacked a clear legal right justifying injunctive relief.
Assertions that the prospective damages, if any, were compensable by monetary award and that the RTC’s order effectively disposed of the case on merit without proper evaluation of all evidence.

On June 22, 1994, the CA issued a temporary restraining order against the RTC orders, and on July 22, 1994, the CA rendered a decision annulling the RTC orders and dismissing Civil Case No. Q-94-20557.
CATALINA’s subsequent motion for reconsideration before the CA was denied in November 1994.

Exceeded its jurisdiction by dismissing the main action for damages and injunction.
Reviewed and reversed the factual findings and evidentiary evaluation of the RTC, which should fall under the ambit of an appeal rather than a certiorari proceeding.
Interfered with the RTC’s discretionary power in issuing a writ of preliminary injunction based on the “incomplete” evidence presented during the preliminary phase.

Whether the Court of Appeals, in a certiorari proceeding assailing an interlocutory order, had the jurisdiction to review and reverse the trial court’s findings and dismiss the main action for damages and injunction pending before the RTC.
Whether the trial court abused its discretion in issuing the writ of preliminary injunction based on preliminary and incomplete evidence.
Whether the CA’s dismissal of the main case, which remained pending and had not been finally adjudicated on its merits, was justified.
Whether the CA overstepped its boundaries by delving into the merits of the main case despite the established rule that certiorari cannot be raised to correct factual findings.