Land Bank of the Philippines v. Continental Watchman Agency Inc.
REITERATIONFacts
The Antecedents: Land Bank of the Philippines (LBP) published an "Invitation to Pre-Qualify" for security guard services. Continental Watchmen Agency Incorporated (CWAI) and other agencies responded and participated in the public bidding. CWAI submitted bids for three areas and was the lowest bidder for these areas. Procedural History: LBP declared CWAI disqualified due to its bid price being below the prescribed salary and for failing to include night differential pay as required by Bid Bulletin No. 1. CWAI's motion for reconsideration was denied. CWAI filed a petition for injunction and damages with a prayer for a preliminary mandatory injunction before the Regional Trial Court (RTC), Branch 17, Manila. The RTC issued a temporary restraining order (TRO) and subsequently, after hearing both parties, issued a writ of preliminary injunction upon CWAI posting a bond of P50,000.00. LBP filed an Answer with Special and/or Affirmative Defenses and Compulsory Counterclaim. LBP's motion for reconsideration of the injunction order was denied by the RTC. The Petition: LBP filed a Petition for Certiorari and Prohibition with Preliminary Injunction and Temporary Restraining Order before the Court of Appeals (CA), alleging that the RTC orders were issued without jurisdiction or with grave abuse of discretion. The CA dismissed LBP's petition. LBP filed a motion for reconsideration, which was denied. Hence, LBP filed the present petition for certiorari before the Supreme Court, alleging grave abuse of discretion on the part of the CA.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in dismissing LBP's petition for certiorari. Whether the trial court committed grave abuse of discretion in issuing the writ of preliminary injunction.
Ruling
The petition is dismissed. The Court of Appeals did not commit grave abuse of discretion in dismissing LBP's petition for certiorari.
Ratio Decidendi
On the issue of whether the Court of Appeals committed grave abuse of discretion: The Supreme Court held that LBP's remedy was an appeal by way of a petition for review on certiorari under Rule 45, not a petition for certiorari under Rule 65. The petition was filed 43 days after the denial of the motion for reconsideration, exceeding the reglementary period for a Rule 45 petition. The Court reiterated that certiorari cannot be used as a substitute for a lost appeal. While the Court may, in the interest of justice, treat a certiorari petition as a review petition, it found no reason to do so in this case. Furthermore, even assuming the petition was proper, the Court found no grave abuse of discretion on the part of the CA. The CA correctly ruled that the RTC did not commit grave abuse of discretion in issuing the writ of preliminary injunction. The CA emphasized that certiorari is for errors of jurisdiction, not errors of judgment, and grave abuse of discretion implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. The record did not show such an actuation by the RTC judge. The CA also noted that factual matters are not proper for consideration in a certiorari petition, and the grant or denial of an injunction rests on the sound discretion of the trial court, which will not be interfered with except upon a clear abuse of discretion. The CA pointed out that the RTC conducted hearings, heard both parties, and required a bond, indicating that the process was not arbitrary. On the issue of whether the trial court committed grave abuse of discretion in issuing the writ of preliminary injunction: The Supreme Court affirmed the CA's finding that the trial court did not commit grave abuse of discretion. The Court reiterated that the issuance of a writ of preliminary injunction rests on the sound discretion of the trial court, which is given generous latitude in this regard. The Court noted that the trial court found that all requisites for the issuance of an injunctive writ were present based on the evidence presented by CWAI. The Court clarified that an injunctive writ is not a judgment on the merits of the case, as it is generally based on initial and incomplete evidence, and the findings of fact are interlocutory. The sole object of a preliminary injunction is to preserve the status quo until the merits of the case can be heard. The trial court's decision to preserve the status quo was found to be based on an evaluation of the evidence presented by both parties and was not whimsical, arbitrary, or capricious. The Court concluded that there was no manifest abuse of discretion that would warrant interference by appellate courts.
Main Doctrine
A petition for certiorari under Rule 65 is not a substitute for a lost appeal under Rule 45. Moreover, the issuance of a writ of preliminary injunction rests on the sound discretion of the trial court and will not be interfered with by appellate courts except upon a clear showing of grave abuse of discretion, which was absent in this case.