Title
Chief of the Philippine Constabulary vs. Sabungan Bagong Silang, Inc.
Case
G.R. No. L-22609
Decision Date
Feb 28, 1966
A 1963 Mandaluyong ordinance regulating cockfighting was challenged; the Supreme Court annulled a restraining order due to judicial delay and ruled the ordinance invalid, citing prior case law.
A

Case Summary (G.R. No. L-22609)

Background of the Municipal Ordinance

On January 24, 1963, the Municipality of Mandaluyong enacted Municipal Ordinance No. 1, which regulates cockfighting, stipulating that such activities could only occur in duly licensed cockpits. The Ordinance allows the Municipal Mayor to grant permits for cockfighting held for charitable causes but imposes restrictions such as limiting the frequency of such events and ensuring permits are granted at the Mayor’s discretion.

Initiation of Civil Case

On January 30, 1963, Sabungan Bagong Silang, Inc., the license holder for a cockpit in Mandaluyong, initiated Civil Case No. 7544 against the Chief of the Philippine Constabulary. The Corporation alleged that despite holding the necessary permits authorized by the Mayor for cockfights every Wednesday, the petitioner threatened to stop their operations, claiming it constituted a grave abuse of discretion and lack of jurisdiction on the part of the petitioner.

Judicial Proceedings and Injunction

Following the filing of the complaint, Judge Guillermo Torres issued a restraining order against the petitioner on the same day, which restrained the petitioner from interfering with the cockfights. The hearing for a preliminary injunction was set, but various postponements occurred, primarily at the Corporation's request. The petitioner entered a motion for dismissal and sought to lift the restraining order, claiming the legal issues were resolved.

Delay and Allegations of Grave Abuse of Discretion

The petitioner contended that the prolonged delay in resolving the restraining order, which had lasted over three years without a decision from the respondent Judge, amounted to grave abuse of discretion. The petitioner asserted that this inaction exemplified a lack or excess of jurisdiction, warranting the Supreme Court's intervention through certiorari and prohibition.

Legal Precedent and Judgment

The Supreme Court referenced a prior decision in Quimsing vs. Lachica, which invalidated similar municipal ordinances regulating cockpits, highlighting the legal precedent that reinforced the petitioner's argument. Given the failure of the respondent Judge to resolve the restraining order and the established legal framework, the Supre

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