Case Summary (G.R. No. 214073)
Facts
- The provincial hospital established in 1933 was later converted into Bicol Regional Training and Teaching Hospital and eventually renamed Bicol Medical Center (BMC) in 1995.
- In 1982, the Province of Camarines Sur donated approximately five hectares—including Road Lot No. 3—to the Ministry of Health (now the Department of Health), as evidenced by Transfer Certificate of Title No. 13693.
- In 2009, BMC erected a steel gate on Road Lot No. 3. On March 21, 2012, Dr. Nerva issued a memorandum rerouting traffic and closing that gate effective April 1, 2012, to enhance security and accommodate future development (notably a planned Cancer Center Building).
- The closure met community opposition led by Atty. Noe Botor and supported by the Naga City Sangguniang Panlungsod, which passed a resolution authorizing the mayor to dismantle the gate. Instead, the mayor filed for a writ of preliminary injunction before the Regional Trial Court (RTC), where intervenors joined.
Procedural History
- RTC Branch 24 denied the injunctive relief application on December 21, 2012, finding no clear and unmistakable right or threat of irreparable injury. A motion for reconsideration was likewise denied on February 22, 2013.
- The intervenors alone appealed by petition for certiorari to the Court of Appeals (CA), which on February 28, 2014 granted the writ of mandatory preliminary injunction, holding that prima facie evidence of public use sufficed. The CA denied motions for reconsideration on August 26, 2014.
- Petitioners elevated the case by petition for review on certiorari to the Supreme Court and secured a temporary restraining order against enforcement of the CA’s injunctive mandate.
Issue
Whether the Court of Appeals committed reversible error in directing the RTC to issue a writ of preliminary injunction against the closure and relocation of Road Lot No. 3.
Applicable Law
- 1987 Philippine Constitution (public property and due process provisions).
- Rule 58, Rules of Court: procedures and requisites for temporary restraining orders and preliminary injunctions.
- Jurisprudence defining “prima facie evidence,” requisites for preliminary injunction (clear legal right, material invasion, urgency to prevent irreparable injury, lack of adequate remedy), and the nature of ancillary remedies.
- Presidential Decree No. 1818 and Supreme Court Administrative Circular No. 11-2000 (prohibiting injunctions against government infrastructure projects).
Discussion
- Prima facie evidence is “good and sufficient on its face” to establish a fact if unrebutted. A preliminary injunction requires an applicant to show a clear legal right in esse, a material and substantial invasion of that right, urgency to prevent irreparable harm, and absence of an adequate legal remedy.
- Respondents relied on the 1970s Assessor’s Tax Mapping Control Roll, identification maps, community testimony, and customary use to support public character of Road Lot No. 3.
- Petitioners presented Transfer Certificate of Title No. 13693 in favor of the Department of Health (covering Road Lot No. 3) and a December 14, 2012 certification from the Naga City Engineer confirming that the service road is not among city‐maintained roads.
- The trial court weighed both
Case Syllabus (G.R. No. 214073)
Procedural History
- Petitioners Bicol Medical Center (BMC) and the Department of Health (DOH) filed a Petition for Review on Certiorari before the Supreme Court (G.R. No. 214073) assailing the Court of Appeals’ February 28, 2014 Decision and August 26, 2014 Resolution in CA-G.R. SP No. 129806.
- The Court of Appeals had granted a petition for certiorari filed by the Intervenors (Atty. Botor et al.) and directed the Regional Trial Court (RTC) of Naga City to issue a writ of mandatory preliminary injunction against the closure and relocation of Road Lot No. 3.
- Petitioners secured a Temporary Restraining Order (TRO) from the Supreme Court on October 8, 2014, enjoining implementation of the Court of Appeals’ injunctive order, and were required to await further pleadings.
- Respondents filed their Comment (January 13, 2015) disputing petitioners’ characterization of Road Lot No. 3 as private property and sought lifting of the TRO; petitioners replied and attached construction photos.
- The sole issue before the Supreme Court was whether the Court of Appeals erred in directing issuance of a writ of preliminary injunction on the closure of Road Lot No. 3.
Factual Background
- The Camarines Sur Provincial Hospital was established in 1933 along Mabini Street, Naga City; it was later converted into Bicol Regional Training and Teaching Hospital and ultimately into Bicol Medical Center in 1995.
- In 1982, the Provincial Government donated approximately five (5) hectares, including the hospital premises and Road Lot No. 3 (a service road leading from Panganiban Road to J. Miranda Avenue), to the Ministry of Health (now DOH), evidenced by TCT No. 13693.
- In 2009, BMC erected a steel gate along J. Miranda Avenue to regulate traffic into the hospital compound.
- On March 21, 2012, BMC’s Chief I, Dr. Efren SJ. Nerva, issued Hospital Memorandum No. 0310 rerouting traffic inside the compound effective April 1, 2012, closing the J. Miranda Avenue gate to vehicles and pedestrians.
- Community criticism followed; on May 19, 2012, Atty. Noe Botor wrote to the Naga City Mayor to dismantle the gate as a public nuisance. The Sangguniang Panlungsod authorized dismantling, but Mayor Bongat instead filed a Verified Petition for Writ of Preliminary Injunction (Civil Case No. 2012-0073, RTC Branch 24, Naga City).
- Intervenors (Botor et al.) joined; ground-breaking for a Cancer Center Building planned to occupy about three-fourths of Road Lot No. 3 occurred soon thereafter,