Case Summary (G.R. No. 78592)
Background of the Case
Libangang Malolos, Inc. has operated its cockpit since 1914. In January 1985, the Acting Mayor of Malolos denied the renewal of its operational license based on municipal resolutions prohibiting its operation within a designated area. Following this, Libangang filed a complaint with the PGC to contest the Mayor's decision and sought permission to resume operations pending the resolution of this complaint. The PGC granted Libangang permission to operate, leading the Municipality to file an injunction case in the Regional Trial Court (RTC) to restrain the cockfight activity and challenge the PGC's jurisdiction.
Judicial Proceedings
The RTC initially dismissed the Municipality's complaint for lack of merit and jurisdiction, but this decision was reversed by RTC Judge Felipe Villajuan, Jr., who issued an injunction against Libangang's operations. The PGC and Libangang subsequently filed a petition with the Court of Appeals to annul the RTC's ruling. The appellate court found that the RTC lacked jurisdiction over the PGC and affirmed that the authority of the municipal corporation to issue licenses for cockpits was not absolute but subject to the need for review by the PGC.
Jurisdictional Issues
The main issues for resolution were twofold: Whether the RTC had jurisdiction to review the PGC's orders and whether the authority of municipal mayors to issue licenses for cockpits is subject to PGC review and supervision. The Court of Appeals determined that the RTC lacked jurisdiction to intervene in the PGC's authority based on Batas Pambansa Blg. 129, which confers exclusive appellate jurisdiction to review decisions of regional trial courts and quasi-judicial agencies to the Court of Appeals.
Authority of the Municipal Mayor
In rebuttal to the appellate court's determination regarding the authority of municipal mayors, the Supreme Court clarified that mayors, under applicable Philippine law, possess the primary authority to issue licenses for ordinary cockpits. The PGC's role is limited to the regulation of only international cockfighting events and does not extend to ordinary cockpit operations. Consequently, the Supreme Court reinforced that municipal mayors exercise discretion in licensing, independent of PGC oversight.
Legal Interpretation of Powers
The legal interpretation documents from the Hee Acusar case outline that the powers of review and supervision granted to the PGC do not equate to control over municipal decisions regarding ordinary cockpits. The Supreme Court emphasized that "supervision" does not permit the
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Case Overview
- The case is a Petition for Review on Certiorari filed by the Municipality of Malolos against Libangang Malolos, Inc. and the Philippine Gamefowl Commission.
- The Municipal Court sought to reverse the Court of Appeals' decision, which determined that the Regional Trial Court (RTC) lacked jurisdiction over the controversy and that the authority of municipal authorities to issue licenses for cockpits was not absolute, being subject to the control of the Philippine Gamefowl Commission (PGC).
Background of the Case
- Libangang Malolos, Inc. has been operating the Malolos Cockpit Arena since 1914.
- Prior to the expiration of its license, Libangang applied for renewal in 1985, but the Acting Mayor denied it based on local resolutions prohibiting its operation in a restricted area.
- Following the denial of renewal, Libangang filed a complaint with the PGC seeking a review of the Mayor’s action and permission to resume operations.
- The PGC granted Libangang permission to operate on January 31, 1985, which prompted the Municipality to file an injunction case against Libangang and the PGC.
Legal Proceedings
- The RTC dismissed the Municipality's injunction case, citing lack of merit and jurisdiction, leading the Municipality to file a motion for reconsideration.
- The RTC Judge Villajuan later granted the Municipality’s motion, issuing a preliminary injunction against Libangang’s operation