Municipality of Malolos v. Libangang Malolos, Inc.
REITERATIONFacts
The Antecedents: Libangang Malolos, Inc. (Libangang) had been operating the Malolos Cockpit Arena since 1914. Upon seeking renewal of its license for 1985, the Acting Mayor of Malolos denied it, citing Sangguniang Bayan Resolutions disallowing its operation due to its location within a prohibited area. Procedural History: Libangang filed a complaint with the Philippine Gamefowl Commission (PGC) seeking a review of the Mayor's action and authority to resume operations pending hearing. The PGC issued a Resolution allowing Libangang to resume operations. Consequently, the Municipality of Malolos filed a Petition for certiorari and Prohibition with the Regional Trial Court (RTC) to enjoin Libangang's operation and question the PGC's jurisdiction. The PGC moved to dismiss the RTC case, asserting exclusive appellate jurisdiction vested in the Court of Appeals under B.P. Blg. 129. The RTC initially dismissed the case for lack of merit and jurisdiction, but upon reconsideration, a different RTC judge set aside the dismissal and issued a Writ of Preliminary Injunction against Libangang's operation. The PGC and Libangang then filed a Petition with the Court of Appeals to annul the RTC orders. The Court of Appeals reversed the RTC orders, dissolved the injunction, and ruled that the RTC had no jurisdiction over the PGC and the subject matter, as the PGC's earlier assumption of jurisdiction precluded the RTC's authority. The Court of Appeals denied a motion for reconsideration. The Petition: The Municipality of Malolos sought to reverse the Court of Appeals' Decision, particularly its findings on the RTC's lack of jurisdiction and the PGC's authority over municipal cockpit licenses.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction to review the Orders of the Philippine Gamefowl Commission (PGC). Whether the Municipal Mayor's authority to issue a license to operate a cockpit is subject to review and supervision by the PGC.
Ruling
The judgment under review is REVERSED in so far as it holds that the power of City and Municipal Mayors to grant a license to operate a cockpit is subject to control by the Philippine Gamefowl Commission, but AFFIRMED as regards the ruling that the Regional Trial Court has no jurisdiction over the Philippine Gamefowl Commission and the subject matter of this case.
Ratio Decidendi
On the issue of RTC jurisdiction over the PGC: The Court affirmed the ruling of the Court of Appeals that the RTC has no jurisdiction over the PGC and the subject matter of the case. This is primarily based on Section 9(3) of Batas Pambansa Blg. 129 (The Judiciary Reorganization Act of 1980), which vests exclusive appellate jurisdiction over final judgments, decisions, resolutions, orders, or awards of Regional Trial Courts and quasi-judicial agencies in the Intermediate Appellate Court (now Court of Appeals). The Interim Rules of Court and the Rules of Procedure of the Philippine Gamefowl Commission also support this, stating that appeals from the PGC are to the Intermediate Appellate Court. The Court reasoned that a court cannot interfere with the judgments of a court of concurrent or coordinate jurisdiction, and by analogy, the RTC has no jurisdiction over the PGC. The fact that the RTC order might not have been final did not divest the appellate court of its jurisdiction. On the issue of PGC's authority over municipal cockpit licenses: The Court reversed the ruling that the PGC's power over municipal cockpit licenses is one of control. It reiterated the distinction between 'supervision and review' and 'control' as elucidated in the Hee Acusar case. The Court clarified that municipal mayors, with the concurrence of their respective Sanggunians, have the primary power to license and regulate ordinary cockpits, subject only to the guidelines laid down by the PGC. The PGC's power is limited to review and supervision, not control, meaning it can ensure compliance with laws and correct errors but cannot substitute its discretion for that of the local authorities in granting licenses. The Court found the reliance on Section 4 of P.D. No. 1802-A misplaced as 'review and supervision' do not equate to 'control'. The PGC cannot substitute its own discretion for that of the municipal authorities in determining who should be issued a permit or license to operate an ordinary cockpit.
Main Doctrine
The power of review and supervision of the Philippine Gamefowl Commission over municipal cockpit operations is not synonymous with control, and the Regional Trial Court lacks jurisdiction to review decisions of the Philippine Gamefowl Commission, which falls under the exclusive appellate jurisdiction of the Court of Appeals.