Case Summary (G.R. No. 93924)
Sequence of Events
On July 4, 1990, the petitioners filed a petition for certiorari, combined with a motion for a preliminary injunction and/or temporary restraining order, aimed at nullifying NEA’s Resolution No. 51, which dismissed the BENECO Board of Directors. The petition raised urgent concerns about armed military personnel allegedly involved in forcibly taking over BENECO’s operations. Subsequent communications on July 11 and July 25 indicated growing tensions and the risk of violence as BENECO employees resisted this takeover.
Supplemental Petition and Responses
On August 23, 1990, the petitioners filed a supplemental petition emphasizing the ongoing threats posed by NEA personnel. The Supreme Court required NEA to respond to the petitioners' requests, which was duly submitted by the Solicitor General. The response outlined four primary defenses against the petition: allegations of forum shopping, failure to exhaust administrative remedies, proper warrant for the dismissal of the BENECO board, and fulfillment of due process rights.
Forum Shopping Allegations
The Solicitor General argued that the petitioners engaged in forum shopping by simultaneously pursuing a case in the Regional Trial Court of Baguio City with similar claims against NEA. This was demonstrated through documents evidencing that BENECO’s complaint had been filed with similar allegations, resulting in a temporary restraining order granted by the trial court.
Court’s Initial Resolution
On October 10, 1990, the Supreme Court resolved to dismiss the petition, stating that BENECO failed to show grave abuse of discretion on NEA’s part. The Court found that due process was afforded to the dismissed board members. Furthermore, it directed Hamada and Atty. Emiliano L. Gayo to explain why they should not face contempt charges for the simultaneous filings, emphasizing the seriousness of engaging in forum shopping.
Justifications and Court’s Findings
In response, Hamada and Gayo filed justifications, claiming that the civil suit was distinct and required evidence presentation, presenting it as an honest mistake regarding simultaneous filings to protect BENECO’s interests. However, the Court rejected these justifications, noting that both cases arose from the same set of facts and that filing in two forums undermined the integrity of judicial processes. The Court reiterated that the purpose of prohibiting forum shopping is to maintain faith in the justice system.
Final Court Orders
The Court ultimately ruled on November 10, 1990, granting the motion for contempt against Hamada and Gayo for their dual filings. The Cour
...continue readingCase Syllabus (G.R. No. 93924)
Case Background
- The case involves a petition for certiorari filed by Benguet Electric Cooperative, Inc. (BENECO), its Board of Directors, and Baguio-Benguet Community Credit Cooperative, Inc. against the National Electrification Administration (NEA).
- The petitioners sought to nullify Resolution No. 51 issued by NEA which dismissed the BENECO Board of Directors and to inhibit NEA from taking over BENECO's management.
- The petition was verified by Sinai C. Hamada, BENECO's Board President, and Gregorio S. Rimas, President and Chairman of the Board of the credit cooperative.
Sequence of Events
- On July 4, 1990, the petition was filed with an urgent request for a preliminary injunction or temporary restraining order.
- By July 11, 1990, a telegram from Atty. Gayo indicated that armed military personnel were attempting to forcibly take over BENECO's operations, leading to potential violence from employees and consumers resisting the takeover.
- A supplemental petition was filed on August 23, 1990, reiterating concerns over NEA's persistent takeover attempts.
NEA's Response
- NEA, represented by the Solicitor General, filed a comment on the petition asserting several grounds:
- Allegations of forum shopping by petitioners.
- Failure to exhaust administrative remedies prior to filing the petition.
- Lack of abuse of discretion by NEA in dismissing BENECO's Board.
- Assertion that due process was affo