Trinidad v. Moya
REITERATIONFacts
The Antecedents: Petitioners Anacleto Trinidad and Dionisio Barroga were leased the Iriga Central Market and Sagrada Market, respectively, by the Municipal Mayor of Iriga, pursuant to a resolution approved by the Municipal Court and later by the Municipal Council. The lease agreements were for one year, commencing January 1, 1960, with options for extension, and rentals were paid quarterly in advance. Petitioners took over the operation and administration of the markets. Procedural History: The Municipality of Iriga filed a civil action (Civil Case No. 4836) against petitioners and the former mayor to annul the lease contracts. The Municipality prayed for a writ of preliminary injunction to restrain petitioners from collecting rents and fees during the pendency of the action, alleging fraud, collusion, and intent to defraud the municipality, and that continued collection would cause irreparable injury. Petitioners' motion to require the municipality to specify the alleged fraud was denied. Petitioners filed an answer asserting the legality of the lease contracts and alleging the suit was politically motivated. On March 22, 1960, the respondent judge issued a preliminary injunction ex parte, finding that the municipality was entitled to the relief sought and would suffer irreparable injury if the writ was not issued immediately, noting that the defendants had not denied the facts supporting the injunction. Petitioners' motion to set aside the injunction was denied. The Petition: Petitioners filed a petition for certiorari, alleging that the respondent judge committed a grave abuse of discretion in issuing the writ of preliminary injunction ex parte and in denying their motion to set it aside.
Issue(s)
Whether the respondent judge committed a grave abuse of discretion in issuing the writ of preliminary injunction ex parte. Whether the respondent judge committed a grave abuse of discretion in denying petitioners' motion to set aside the writ of preliminary injunction.
Ruling
The petition is denied, with costs.
Ratio Decidendi
On the issue of grave abuse of discretion in issuing the writ of preliminary injunction ex parte: The Court found no merit in the petitioners' claim. While the general rule is that a writ of preliminary injunction should be issued only after notice, the Rules of Court allow for ex parte issuance upon a showing of irreparable injury. In this case, the allegations in the complaint, verified by the Provincial Fiscal, indicated that the municipality was entitled to the relief sought. The continued collection of rents and fees by the lessees would likely cause irreparable injury to the municipality, as it would be difficult to ascertain the exact amounts collected by private individuals if the lease contracts were eventually annulled. The Court reiterated its policy not to interfere with the trial court's discretion in granting or denying relief unless there is a clear and serious abuse thereof, which was not obtaining in this case. The Court also noted that the defendants had not denied the facts averred in support of the injunction in their answer. On the issue of grave abuse of discretion in denying the motion to set aside the writ of preliminary injunction: The Court found no grave abuse of discretion. The reasoning for issuing the writ ex parte, as detailed above, also supported the denial of the motion to set it aside. The trial court had already considered the circumstances and found sufficient grounds to maintain the injunction pending the resolution of the main case. The Court emphasized that on matters where trial courts are given discretion, its policy is not to interfere unless there is a clear and serious abuse, which was not demonstrated by the petitioners.
Main Doctrine
A writ of preliminary injunction may be issued ex parte upon a showing that the party seeking the injunction will suffer irreparable injury if the writ is not issued immediately. The trial court's discretion in granting or denying relief will not be interfered with unless it is clearly shown that it was abused in a serious manner.