Aboitiz v. Regino
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the National Power Corporation's (NAPOCOR) agreement with Ferrochrome Philippines, Inc. (FPI) for the direct sale and supply of electricity to FPI's plant. Cagayan Electric Power and Light Company, Inc. (CEPALCO), which holds a franchise for the area where FPI is located, contended that this agreement violated its franchise rights and national electrification policies. CEPALCO argued that NAPOCOR should not be directly supplying power to FPI, but rather that any such supply should be coursed through CEPALCO's distribution lines. 2. Procedural History: CEPALCO initially filed a petition for prohibition, mandamus, and injunction against NAPOCOR before the Regional Trial Court (RTC) of Quezon City. The RTC ruled in favor of CEPALCO, permanently enjoining NAPOCOR from directly supplying electricity to FPI and ordering that such supply be coursed through CEPALCO. This decision was affirmed by the Supreme Court. Subsequently, FPI filed a new application for direct power supply from NAPOCOR. In response, CEPALCO filed a petition for contempt against the officers of NAPOCOR (the petitioners herein) for allegedly disobeying the RTC's earlier decision. The RTC found the petitioners guilty of indirect contempt and imposed a fine, also ordering an alias writ of execution to enforce the injunction. Reconsideration was denied. 3. The Petition: The petitioners, officers of NAPOCOR, challenge the RTC's orders finding them guilty of indirect contempt. They argue that the Supreme Court's affirmation of the RTC's decision was based on the lack of a hearing for FPI's first application and that the injunction was limited to that specific instance. They contend that the injunction does not cover future applications for direct power supply from NAPOCOR, and therefore, entertaining FPI's new application did not constitute disobedience. CEPALCO counters that the injunction was permanent and unambiguous, prohibiting any future direct supply arrangements between NAPOCOR and FPI. The core issue before the Supreme Court is the scope of the injunction and whether the petitioners' actions in entertaining FPI's new application constituted contempt of court.
Issue(s)
Whether the petitioners, as officers of NAPOCOR, are guilty of indirect contempt for entertaining FPI's new application for direct power supply from NAPOCOR, despite a prior permanent injunction; and whether the scope of the injunction is limited to the specific instance of FPI's first application, considering the argument of functus officio. Whether the trial court correctly implemented its decision and committed no reversible error in finding the petitioners in contempt, thereby making them personally liable for their actions.
Ruling
The petition is DENIED. The contempt orders against the petitioners are affirmed. The temporary restraining order dated January 11, 1993, is LIFTED.
Ratio Decidendi
On the scope of the injunction and the issue of functus officio: The Supreme Court affirmed the trial court's decision that the injunction against NAPOCOR was permanent and comprehensive, meaning it was intended to last indefinitely without change. The injunction explicitly prohibited NAPOCOR from "effecting, causing, and continuing the direct supply, sale and delivery of electricity from its power line to the plant of Ferrochrome Philippines, Inc., and from entering into and/or implementing any agreement or arrangement for such direct power connection, unless coursed through the power line of the petitioner." This prohibition extended to any future agreements or arrangements of the same nature. The argument that the decision had become functus officio was rejected because the permanence of the order meant it continued to have binding effect, and any attempt by NAPOCOR or its officers to enter into a new deal with FPI for direct power connection would constitute a clear and direct disobedience to a lawful court order. On the finding of contempt: The Court found that the trial court correctly implemented its decision of May 2, 1984, and committed no reversible error in finding the petitioners in contempt. The petitioners, as officers of NAPOCOR, were personally liable for their actions in entertaining FPI's re-application, which was a direct defiance of the permanent injunction. The contempt finding was against the individuals and not against NAPOCOR itself, which was not a party to the contempt proceeding. Therefore, their actions in entertaining the new application were a clear violation of the court's order, warranting the finding of indirect contempt.
Main Doctrine
Officers of a government agency found guilty of indirect contempt for disobeying a permanent injunction are personally liable for the fine imposed, and the injunction's scope, once affirmed by the Supreme Court, permanently prohibits the prohibited acts, including future applications of the same nature.