Title
Supreme Court
De Lima vs. Court of Appeals
Case
G.R. No. 199972
Decision Date
Aug 15, 2022
CEZA revoked Meridien's jai alai license; GAB issued a CDO for off-frontons. Courts ruled on jurisdiction, judicial courtesy, and regulatory authority, limiting GAB's scope to off-frontons.

Case Summary (G.R. No. 199972)

Applicable Law

The case hinges on interpretations of various laws, including the Revised Rules of Court, Republic Act No. 954, and several rulings of the Supreme Court.

Factual Background

CEZA granted Meridien a license for gaming operations, including jai alai activities within CSEZFP. The Office of the Government Corporate Counsel later advised CEZA that it lacked the authority to license jai alai without a legislative franchise, leading CEZA to revoke the license. Meridien contested this revocation through a Regional Trial Court (RTC) writ of mandamus, which was issued in their favor but later became final due to counsel negligence, prompting further legal maneuvering.

Proceedings of the GAB

Meanwhile, the GAB, through an investigation, uncovered several off-frontons operating without permits. GAB issued a Cease-and-Desist Order (CDO) against these off-frontons, which prompted Meridien to file for an injunction against the CDO. The RTC of Aparri issued provisional injunctive orders that GAB later contested before the Court of Appeals, arguing a lack of jurisdiction and the GAB's regulatory authority over jai alai activities.

Court of Appeals’ Decisions

In CA-G.R. SP No. 119842, the CA ruled in favor of GAB, asserting that the CDO was valid and exercised appropriate regulatory authority despite Meridien's claims of operating under CEZA's license. However, the CA later partially modified this ruling, limiting GAB's authority to areas outside CSEZFP.

Issues in G.R. No. 199972

Petitioners in G.R. No. 199972 contended that the CA erred by granting a Writ of Preliminary Injunction (WPI) and holding the resolution of CA-G.R. SP No. 120236. The main issues focused on whether the CA exercised grave abuse of discretion in its actions and whether it possessed jurisdiction to resolve the case at hand.

Rulings on Preliminary Injunction

The Court emphasized that judicial courtesy cannot substitute for a clear legal right needed to justify the issuance of a WPI. Notably, the CA's reliance on judicial courtesy was misplaced, especially since the issue on CEZA's authority had already been resolved by the Supreme Court, guiding the CA to proceed without delay. Furthermore, the Court clarified that the issuance of a WPI is contingent on a demonstrated legal right, which Meridien failed to establish for off-fronton operations in light of RA 954’s prohibitions.

G.R. No. 206118 Issues

In G.R. No. 206118, GAB argued that the CA erred in clarifying that the CDO pertained only to off-frontons. The CA upheld the finality of the CDO but encountered criticisms for improperly adjudicating GAB's regulatory authori

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