Case Summary (G.R. No. L-22002)
Background of the Dispute
In August 1960, the appellants were charged in Criminal Cases Nos. 1778 and 1785 for violating Municipal Ordinance No. 20, which prohibits trawl fishing. Following their plea of not guilty, the appellants filed a motion to quash the complaints, arguing that the ordinance had been disapproved by the Secretary of Agriculture and Natural Resources on March 12, 1957. The Justice of the Peace, Sabarre, denied this motion and set the cases for trial in 1961.
Legal Proceedings in the Court of First Instance (CFI)
On May 15, 1961, the appellants commenced an action in the Court of First Instance of Samar seeking a writ of prohibition and mandamus to restrain the enforcement of the municipal ordinance. They sought to annul the ordinance, compel Sabarre to quash the complaints, refund P800 allegedly collected under the ordinance, and recover damages. The respondents denied several allegations and provided affirmative defenses, including the assertion that the complaint lacked a valid cause of action.
CFI's Ruling
During the hearing on July 23, 1963, the appellants' counsel argued that Sabarre lacked jurisdiction due to the legality of the municipal ordinance being in question. However, the CFI ruled that Sabarre should proceed with the trial of the criminal cases, asserting that the appellants could appeal any potential judgement following that trial. The CFI subsequently dismissed the motion to quash, stating that it was meritless due to the absence of a clear legal basis for the claims provided by the appellants.
Appeal and Legal Analysis
In their appeal, the appellants contended that the lower court erred by dismissing the complaint without a full hearing and in not recognizing the alleged jurisdictional excess by the Justice of the Peace and the Mayor. The court clarified that a writ of prohibition is only applicable when a party acts beyond their jurisdiction or shows grave abuse of discretion. It underscored that a motion to quash relies primarily on judicial discretion and that prohibition is not an appropriate remedy for reviewing a motion denial.
Examination of the Ordinance's Validity
The ordinance's disapproval was cited by the appellants as the basis for their quash motion. However, they failed to demonstrate when the ordinance was submitted to the Secretary or to affirm that the
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Case Background
- Petitioners Canuto A. Lim and Lorenza Alcoy own two fishing boats, with the crew members being co-appellants.
- In August 1960, they were accused of violating Municipal Ordinance No. 20 series of 1956, which prohibits trawl fishing.
- After pleading not guilty, the appellants filed a motion to quash the complaints on September 3, 1960, citing the ordinance's disapproval by the Secretary of Agriculture and Natural Resources on March 12, 1957.
Proceedings in the Justice of the Peace Court
- Justice of the Peace Tomas V. Sabarre denied the motion to quash and set trial dates for March 25 and April 3, 1961, which were postponed.
- On May 15, 1961, appellants filed an action in the Court of First Instance (CFI) of Samar against Sabarre, Municipal Mayor Ildefonso S. Abancio, and Municipal Treasurer Jose Latorre.
- The action sought a writ of prohibition and mandamus to restrain the enforcement of the ordinance and to compel Sabarre to quash the complaints.
Respondents' Answer and Defenses
- Respondents admitted some allegations and denied others while asserting affirmative defenses:
- The complaint lacked a cause of action.
- No written notice of disapproval had been provided to the Municipa