Title
Boiser vs. Court of Appeals
Case
G.R. No. L-61438
Decision Date
Jun 24, 1983
Boiser operated a telephone system in Bohol under an agreement with PLDT. PLDT disconnected services without notice, prompting Boiser to seek injunctive relief. The Supreme Court ruled the CFI had jurisdiction, emphasizing public interest and procedural errors by the Court of Appeals.

Case Summary (G.R. No. L-61438)

Background of the Case

In August 1965, the petitioner and PLDT entered into an Interconnecting Agreement that allowed PLDT to provide long-distance and overseas telephone services to the petitioner via its relay station in Mandaue City, Cebu. Under this agreement, PLDT had the obligation to maintain the necessary facilities, while the petitioner had various responsibilities regarding operational standards and maintenance.

Issuance of the Circuit Authorization Order

On February 27, 1979, PLDT unilaterally issued a circuit authorization order to terminate its connection with the petitioner’s facilities, claiming a violation of their agreement. This action was executed without prior notification to the petitioner, prompting Boiser to seek judicial intervention through a civil case for injunction and damages.

Court of First Instance's Restraining Order

The Court of First Instance issued a temporary restraining order on March 2, 1979, to preserve the status quo between the parties. However, after several months, PLDT filed a motion to lift this order, and the matter was presented for a hearing where it was agreed to tackle the merits alongside the request to dissolve the restraining order.

Escalation to the Court of Appeals

On July 20, 1982, nearly three years after the initial restraining order, PLDT filed a petition for certiorari with the Court of Appeals, challenging the validity of the restraining order. The petition posited that the issue was under the jurisdiction of the National Telecommunications Commission, not the Court of First Instance.

Response from the Court of Appeals

The Court of Appeals issued a resolution that effectively allowed respondents to suspend enforcement of the restraining order while requiring comments from the respondents. This resolution prompted the petitioner to bring the matter before the Supreme Court, arguing that the Court of Appeals exceeded its jurisdiction.

Jurisdictional Matters

The primary jurisdictional dispute revolved around whether the subject matter fell under the authority of the National Telecommunications Commission or the courts. PLDT asserted that the disconnection was an internal matter, while Premiere contended that the courts needed to adjudicate the matter due to the potential infringement of contractual rights.

Examination of the Interconnecting Agreement

The agreements between the parties stipulate that a violation of the contract could lead to disconnection only after appropriate notice had been given. The requisite notification period and conditions surrounding disconnection were central to the analysis. The Court found that procedural requirements must be respected, and any claims of contract breach warrant examination in court rather than administrative channels.

Court's Findings

The Supreme Court underscored that the case was rooted in breach of contract allegations, emphasizing t

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