D.C. Crystal, Inc. v. Laya
REITERATIONFacts
The Antecedents: Corazon Y. Lua filed a complaint against Desamparado C. Crystal and D.C. Crystal, Inc. (petitioner) for allegedly disturbing her business operations. Lua claimed she was lawfully engaged in supplying crushed aggregates from a quarry with permits from the Bureau of Mines. She alleged that on February 25, 1980, the defendants, claiming her area was within their concession, destroyed a road she constructed for access and prevented her trucks from loading and hauling aggregates. This immobilized her equipment and caused her continuing damages. Lua sought a temporary restraining order (TRO) and preliminary injunction, averring great and irreparable injury. Procedural History: The respondent Judge issued an Order dated February 26, 1980, granting a TRO upon Lua's filing of a bond, ordering the defendants to cease disturbing Lua's business operations and preventing her from hauling aggregates. The hearing for the preliminary injunction was set for March 4, 1980. The defendants filed motions to dismiss the action for improper venue and lack of cause of action, and to dissolve the restraining order. After a hearing, oral arguments, and an ocular inspection, the respondent Judge denied both motions in an Order dated March 24, 1980, and granted the preliminary injunction. The Petition: D.C. Crystal, Inc. filed a special civil action for certiorari and prohibition, seeking to annul the orders of February 26, 1980, and March 24, 1980. The Supreme Court issued a restraining order on April 18, 1980, enjoining the enforcement of the lower court's orders and further proceedings, except for reception of evidence on damages allegedly suffered by petitioner.
Issue(s)
Whether the respondent Judge acted without or in excess of jurisdiction in issuing the restraining order and preliminary injunction, considering Presidential Decree No. 605 and Presidential Decree No. 1281 which allegedly grant exclusive jurisdiction to the Bureau of Mines over cases involving mining concessions. Whether the venue of the action was improperly laid. Whether the respondent Judge erred in denying the motion to dismiss for failure to state a cause of action.
Ruling
The petition is DISMISSED, and the petitioner's motion for contempt is DENIED, for lack of merit. The temporary restraining order of April 18, 1980, is SET ASIDE. Costs against petitioner.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court held that the respondent Judge did not act without or in excess of jurisdiction. While PD 605 and PD 1281 grant exclusive jurisdiction to the Bureau of Mines over certain mining-related matters, Lua's complaint was founded on the theory that the defendants unlawfully intruded into her area of operations, destroyed her road, immobilized her equipment, and caused her damages. The complaint did not put at issue the legitimacy of the defendants' mining lease contracts but rather asserted that the defendants violated Lua's rights by taking the law into their own hands. This factual situation, involving alleged unlawful acts and damages, is not exclusively within the jurisdiction of the Bureau of Mines. Furthermore, the injunction restrained the defendants' invasion of Lua's operations area and infringement of her rights, not their mining activities per se. The Court also noted that the respondent Judge's findings, based on evidence and ocular inspection, supported the existence of a prima facie case for injunctive relief. On the issue of venue: The Supreme Court found no merit in the petitioner's theory of improper venue. The action was characterized as personal, seeking recovery of damages caused by intimidation and illegal means to prevent business activities, and to destroy property. According to Section 2(b) of Rule 4 of the Rules of Court, venue for such actions may be laid at the plaintiff's place of residence, at the latter's option. The Court also dismissed the insistence on trying the case in Cebu City instead of Mandaue City as a mere quibbling over something of no consequence, affecting no conceivable matter of substance. On the issue of cause of action: The Supreme Court affirmed that the respondent Court acted correctly in denying the motion to dismiss for failure to state a cause of action. It is axiomatic that a defendant moving to dismiss on this ground is deemed to have hypothetically admitted all the averments in the complaint. The test is whether, admitting the facts alleged, the court could render a valid judgment. The Court reiterated that in determining the sufficiency of the complaint, only the statements within the complaint should be considered, and it is error to take cognizance of external facts not pleaded therein, such as the lease contract not being in Lua's name or her alleged disqualification as a Chinese national. These external facts are proper for affirmative defenses in the answer, not for a motion to dismiss based on lack of cause of action.
Main Doctrine
The Court of First Instance retains jurisdiction to issue injunctive relief in cases involving disputes over property rights and business operations, even if mining rights are peripherally involved, provided the core issue is not the validity of the mining concession itself but the unlawful acts of parties causing damage and disruption. Venue is properly laid in the place of residence of the plaintiff in actions for damages and recovery of property rights. A motion to dismiss based on lack of cause of action hypothetically admits the allegations in the complaint, and external facts not pleaded therein cannot be considered at that stage.