Regalado v. Provincial Constabulary Commander
REITERATIONFacts
The Antecedents: Petitioners, engaged in deep-sea fishing, purchased ice in Bacolod City to be sent to Cadiz, Occidental Negros, for use in their business. The respondent Provincial Commander of the Philippine Constabulary in Occidental Negros, acting upon a request from the Public Service Commission, prevented the entry of this ice into Cadiz. Procedural History: Petitioners filed an action for injunction in the Court of First Instance of Occidental Negros. A writ of preliminary injunction was granted, but the case was subsequently dismissed after trial upon an agreed stipulation of facts, and the preliminary writ was dissolved. The Petition: Petitioners appealed the dismissal, claiming the lower court erred in holding that it lacked jurisdiction to grant an injunction against the respondent and, consequently, in dismissing the case.
Issue(s)
Whether the Court of First Instance has jurisdiction to issue an injunction against the Provincial Commander of the Philippine Constabulary when he is merely enforcing an order of the Public Service Commission. Whether the dismissal of the case and dissolution of the preliminary injunction were proper.
Ruling
The decision appealed from is affirmed, with costs. The Court of First Instance did not err in dismissing the case.
Ratio Decidendi
On the issue of jurisdiction to issue an injunction against the Provincial Commander enforcing an order of the Public Service Commission: The Court held that since the respondent Provincial Commander was merely enforcing an order of the Public Service Commission upon the latter's request, an injunction issued against him would, in effect, be an injunction against the Public Service Commission itself. The Court reiterated its previous ruling that a Court of First Instance has no authority to issue an injunction against the Public Service Commission or any other court or semi-judicial body of equal rank. Therefore, the lower court correctly found that it lacked jurisdiction to grant the injunction sought. The Court noted that for practical purposes, the Public Service Commission should have been made a party defendant in the case. Furthermore, the Court observed that the injunction sought had become unnecessary due to a prior Supreme Court decision in a related case (G.R. No. L-15300) which declared the order of the Public Service Commission void and issued a final injunction against its enforcement. On the propriety of dismissing the case and dissolving the preliminary injunction: Given the lack of jurisdiction of the Court of First Instance to issue an injunction against the Public Service Commission or its enforcers, the dismissal of the case and the dissolution of the preliminary writ of injunction were deemed proper. The Court found no error in the lower court's decision to dismiss the case on jurisdictional grounds. The fact that the issue had already been rendered moot by a subsequent Supreme Court decision further supported the dismissal.
Main Doctrine
A Court of First Instance has no authority to issue an injunction against the Public Service Commission or any other court or semi-judicial body of equal rank.