Case Summary (G.R. No. 117964)
Applicable Law
The 1987 Philippine Constitution governs the decision of this case, alongside relevant provisions from the Rules of Court, particularly Rule 58, which pertains to preliminary and permanent injunctions.
Background and Proceedings
CATALINA was initially awarded a contract for security services to SSS in 1987. After the contract was extended monthly, a public bidding in 1990 resulted in CATALINA losing the contract to Bolinao Security and Investigation Services. In response, CATALINA filed Civil Case No. Q-91-7798 to enjoin the contract award, successfully securing a preliminary injunction. Subsequently, a compromise was reached, allowing CATALINA to continue providing services pending a new bidding process. Despite this agreement, SSS conducted a second bidding which resulted in the contract being awarded to Jaguar, prompting CATALINA to again seek legal remedies.
Injunctive Relief Granted by Trial Court
Following Jaguar's contract execution, CATALINA filed an action for damages and an injunction against SSS, seeking a temporary restraining order to prevent the termination of its services. The trial court granted a temporary restraining order and subsequently issued a writ of preliminary injunction to prevent SSS from terminating CATALINA's services and awarding the contract to Jaguar.
Appeal and Dismissal by the Court of Appeals
Respondent SSS and the Purchase and Bidding Committee members filed a petition for certiorari in the Court of Appeals, challenging the trial court's rulings. The Court of Appeals issued a temporary restraining order against the implementation of the trial court's injunction and later dismissed CATALINA's case, declaring the trial court's orders null and void.
Legal Issues and Grounds for Review
The primary legal issue presented is whether the Court of Appeals had jurisdiction to review and dismiss the trial court’s case based on alleged abuse of discretion when it was supposed to limit its review to the propriety of the preliminary injunction. CATALINA claimed that the Court of Appeals exceeded its jurisdiction by addressing the merits of the underlying case instead of merely reviewing the injunction.
Analysis of the Court's Decision
The Supreme Court analyzed the procedural boundaries within which the Court of Appeals was operating. It emphasized that certiorari is not a vehicle for correcting factual errors or reviewing the merits of a case until it has been fully heard in the trial court. The issuance of a pr
...continue readingCase Syllabus (G.R. No. 117964)
Background of the Case
- This case involves a petition for review filed by Placido O. Urbanes, Jr. against the Court of Appeals and various respondents including the Social Security System (SSS) and members of its Purchase and Bidding Committee.
- The dispute originated from the award of a security services contract by the SSS, which Urbanes’ security agency, Catalina Security Agency (CATALINA), contested due to alleged irregularities in the public bidding process.
- CATALINA was initially awarded a contract in 1987 to provide security services for the SSS, which was later extended until a new bidding was held in 1990, resulting in the contract being awarded to another agency, Bolinao Security and Investigation Services.
Procedural History
- CATALINA filed Civil Case No. Q-91-7798 to enjoin the contract award to Bolinao, resulting in a temporary restraining order issued by the trial court.
- The SSS sought to nullify this order through petitions for certiorari, which were ultimately dismissed by the Court of Appeals.
- A compromise agreement was reached between CATALINA and the SSS, allowing CATALINA to continue providing services until a new bidding was held.
- Following a new public bidding, the contract was awarded to Jaguar Security and Investigation Services (JAGUAR), prompting CATALINA to file another action for damages and injunction, seeking to prevent the termination of its services.
Trial Court's Rulings
- The trial court initially granted a temporary restraining order and subsequently a pr