Case Summary (G.R. No. L-3974)
Background of the Case
The dispute originated from Meralco's petition for declaratory relief, filed in the RTC as Special Civil Action No. 4149-PSG. Meralco sought to declare certain issuances by the Department of Energy (DOE) and ERC regarding the Retail Competition and Open Access (RCOA) provisions of the EPIRA as null and void. In tandem, Meralco requested a temporary restraining order (TRO) and/or a writ of preliminary injunction to prevent the implementation of the disputed issuances. On June 13, 2016, the RTC granted a 20-day TRO favoring Meralco, prompting the ERC to file a petition against this order.
Jurisdiction and Abuse of Discretion
The Supreme Court established that while the RTC properly asserted jurisdiction over the petition for declaratory relief, it exhibited grave abuse of discretion regarding the issuance of the 20-day TRO and subsequent writ of preliminary injunction on July 13, 2016. The decision reinforced the principle that only the Supreme Court holds the authority to enjoin the implementation of the EPIRA under Section 78.
Request for Injunctive Relief
In its petition for certiorari, the ERC claimed that it was denied due process, citing procedural defects including inadequate notice and insufficient time to prepare for the hearings. However, the Supreme Court reiterated that allegations of this nature did not substantiate an urgent necessity for injunctive relief since they did not demonstrate existing rights deserving protection.
Ruling on Jurisdiction Limitations
The Court clarified that the RTC's power was limited to the main declaratory relief petition. It reiterated that no lower court could issue injunctions that would impede the implementation of DOE/ERC issuances related to the EPIRA during the pendency of the case. The RC's action in issuing the 20-day TRO was deemed moot as it h
...continue readingCase Syllabus (G.R. No. L-3974)
Case Reference
- G.R. No. 225141
- Date of Decision: September 26, 2016
- Division: Second Division
- Justice: Brion, J.
Parties Involved
- Petitioner: Energy Regulatory Commission (ERC)
- Respondents:
- Hon. Gregorio L. Vega, Jr., Presiding Judge, Regional Trial Court, Branch 157, Pasig City
- Manila Electric Company (Meralco)
Background of the Case
- The case arose from a petition for declaratory relief filed by Meralco before the Regional Trial Court (RTC), Branch 157, Pasig City, which was docketed as Special Civil Action No. 4149-PSG.
- Meralco sought to declare null and void certain issuances by the Department of Energy (DOE) and the ERC related to the Retail Competition and Open Access (RCOA) provision of the Electric Power Industry Reform Act of 2001 (EPIRA).
- The petition included a request for a Temporary Restraining Order (TRO) and/or a writ of preliminary injunction to suspend the implementation of the DOE/ERC issuances.
RTC Rulings
- On June 13, 2016, the RTC granted Meralco's prayer and issued a 20-day TRO.
- Subsequently, on July 13, 2016, the RTC issued a writ of preliminary injunction based on Meralco's application.
ERC's Petition and Relief Sought
- The ERC filed a petition assailing the RTC's June 13, 2016, order, claiming it constituted grave abuse of discretion.
- ERC sought injunctive relief to prevent the RTC from continuing pro