Republic v. Bayao
REITERATIONFacts
The Antecedents: Executive Order No. 304 designated Koronadal City as the regional center and seat of the SOCCSKSARGEN Region, mandating the transfer of national government regional offices to Koronadal City. In compliance, the Department of Agriculture-Regional Field Unit XII (DA-RFU XII) was directed to transfer its operations from Cotabato City to Koronadal City. However, officials and employees of DA-RFU XII opposed this transfer, citing concerns about costs, employee displacement, and the alleged pronouncement of the President to keep the regional seat in Cotabato City. They also raised issues regarding the suitability of proposed facilities in Koronadal City and the potential financial strain on employees. Procedural History: The DA-RFU XII was directed to transfer its regional seat to Koronadal City. In opposition, the respondent employees filed a Complaint for Injunction with the Regional Trial Court (RTC), Branch 14 of Cotabato City. The RTC granted a Writ of Preliminary Injunction against the transfer. The Republic of the Philippines, represented by DA-RFU XII, filed a Petition for Certiorari with the Court of Appeals (CA) under Rule 65, arguing the RTC order was contrary to Supreme Court pronouncements. The CA dismissed this petition for failure to file a Motion for Reconsideration of the RTC order. The Republic then filed the present Petition for Review on Certiorari under Rule 45 with the Supreme Court, assailing the CA's dismissal. The Petition: The petitioner, Republic of the Philippines, seeks to reverse the CA's dismissal of its Rule 65 petition. The petitioner argues that a Motion for Reconsideration was not necessary before filing the Rule 65 petition, citing exceptions where the issues were already passed upon by the lower court and the urgent necessity for resolution. It contends that the RTC's injunction against the transfer of the DA-RFU XII regional office to Koronadal City was an encroachment on the executive department's powers, contrary to the Supreme Court's ruling in DENR v. DENR Region 12 Employees, which held that the wisdom of such transfers is beyond judicial inquiry. The petitioner asserts that the trial court interfered with the executive's prerogative in managing its affairs and disregarded established rules on administrative issuances and the propriety of injunctions.
Issue(s)
Whether a Petition for Review on Certiorari under Rule 45 is the proper remedy to assail the Court of Appeals' Resolutions dismissing a Petition for Certiorari under Rule 65 for failure to file a Motion for Reconsideration. Whether the exceptions to the requirement of filing a Motion for Reconsideration prior to filing a Petition for Certiorari under Rule 65 are present in this case. Whether the trial court's issuance of a preliminary injunction against the transfer of the DA Regional Office to Koronadal City violates the separation of powers between the executive and judiciary. Whether the Court of Appeals erred in dismissing the Petition for Certiorari for failure to file a Motion for Reconsideration.
Ruling
The Supreme Court GRANTED the Petition. The Resolutions of the Court of Appeals dated March 21, 2007 and August 16, 2007, as well as the Decision dated October 9, 2006 of the Regional Trial Court, Branch 14 of Cotabato City, were REVERSED and SET ASIDE.
Ratio Decidendi
On the propriety of Rule 45: The Court held that a Petition for Review on Certiorari under Rule 45 is the proper remedy to assail a Court of Appeals Resolution that dismissed a Petition for Certiorari under Rule 65 for failure to file a Motion for Reconsideration. The Court reasoned that such dismissal would otherwise lead to the finality of the trial court's order, rendering it unassailable. A dismissal by the Court of Appeals of a Rule 65 petition for failure to file a Motion for Reconsideration is considered a final resolution contemplated under Rule 45, as it is an original and independent action. Therefore, to prevent the trial court's order from becoming unassailable, the CA's resolution must be subject to review via Rule 45. On the exceptions to filing a Motion for Reconsideration: The Court found that the case falls under the exceptions to the rule requiring a Motion for Reconsideration before filing a Petition for Certiorari. Specifically, the exception where "the questions raised in the certiorari proceedings have been duly raised and passed upon by the lower court" was deemed applicable. The Court noted that the issues petitioner raised before the Court of Appeals had already been presented and considered by the trial court in its various pleadings. Thus, the trial court had already been given the opportunity to rule on the propriety of the injunction, making a motion for reconsideration before the trial court unnecessary. On the violation of separation of powers: The Court ruled that the trial court's issuance of a preliminary injunction against the transfer of the DA Regional Office to Koronadal City violated the principle of separation of powers. The Court reiterated its pronouncement in DENR v. DENR Region 12 Employees that the wisdom or expediency of acts of the executive department, such as the transfer of regional offices mandated by an Executive Order, is beyond judicial inquiry. The transfer of the regional center was an executive function, and the judiciary cannot interfere with such decisions. The concerns raised by the respondents, such as the lack of buildings, inconvenience to employees' children's schooling, and costs, were matters addressed to the wisdom of the transfer, not its legality. On the Court of Appeals' dismissal: The Court found that the Court of Appeals erred in dismissing the Petition for Certiorari solely on the ground of failure to file a Motion for Reconsideration, without addressing the substantive issues. Given that the case fell under the exceptions to the rule, the CA should have proceeded to resolve the merits of the petition. The Supreme Court, in the interest of public service and the effective administration of the executive department, chose to disregard procedural flaws to address the substantive issues, emphasizing the need for stability in public service.
Main Doctrine
A Petition for Review on Certiorari under Rule 45 may be used to assail a Court of Appeals Resolution that dismissed a Petition for Certiorari under Rule 65 for failure to file a Motion for Reconsideration, as such dismissal would otherwise lead to the finality of the trial court's order. Furthermore, the exception to the requirement of filing a Motion for Reconsideration applies when the issues raised in the certiorari proceedings have already been passed upon by the lower court, and the judiciary cannot inquire into the wisdom or expediency of acts of the executive department, such as the transfer of regional offices mandated by an Executive Order.