Bicol Medical Center v. Botor
REITERATIONFacts
The Antecedents: The Bicol Medical Center (BMC), formerly the Bicol Regional Training and Teaching Hospital, occupies a parcel of land donated to the Department of Health in 1982, which includes what is known as Road Lot No. 3. In 2009, BMC constructed a steel gate along J. Miranda Avenue to control traffic. In March 2012, BMC issued a memorandum rerouting traffic within the compound, effectively closing the steel gate on J. Miranda Avenue and relocating it to the western side of the hospital for security and to accommodate future development. This closure led to community criticism and a request from Atty. Noe Botor to reopen or dismantle the gate, which was considered a public nuisance. Procedural History: Following the gate closure, the Sangguniang Panlungsod of Naga City authorized its Mayor to dismantle the gate. Instead, the Mayor filed a Verified Petition with Prayer for a Writ of Preliminary Injunction against BMC. Intervenors, including Atty. Botor, were allowed to join the case. The Regional Trial Court denied Naga City's application for injunctive relief, finding no clear right to the writ. The Intervenors' motion for reconsideration was also denied. Subsequently, only the Intervenors filed a petition for certiorari before the Court of Appeals. The Court of Appeals granted the petition, directing the trial court to issue a writ of mandatory preliminary injunction, emphasizing that only a prima facie showing of right was required and that the public had used Road Lot No. 3 since time immemorial. The Court of Appeals later denied motions for reconsideration, clarifying that the injunction pertained to the gate closure and road relocation, not the construction of a Cancer Center Building. The Petition: Petitioners, Bicol Medical Center and the Department of Health, filed a Petition for Review on Certiorari with the Supreme Court, assailing the Court of Appeals' decision. They argued that Road Lot No. 3 was never intended for public use and is part of BMC's private property, evidenced by a certificate of title and a certification from the City Engineer stating it was not a city road. Petitioners contended that the Court of Appeals erred in disregarding their evidence and in holding that the injunction did not violate Presidential Decree No. 1818, which prohibits injunctions against government infrastructure projects, citing the impending construction of the Cancer Center Building. They asserted that respondents failed to establish a clear legal right to the injunctive relief and that the Court of Appeals misappreciated the nature of a preliminary injunction by not considering both parties' evidence.
Issue(s)
Whether the Court of Appeals erred in directing the Regional Trial Court to issue a writ of preliminary injunction on the closure of Road Lot No. 3. Whether respondents established a clear and unmistakable right to utilize Road Lot No. 3 as a public road.
Ruling
The Petition is meritorious. The assailed February 28, 2014 Decision and August 26, 2014 Resolution of the Court of Appeals in CA-G.R. SP No. 129806 are REVERSED and SET ASIDE. The temporary restraining order issued by this Court in its October 8, 2014 Resolution is made PERMANENT.
Ratio Decidendi
On Whether the Court of Appeals erred in directing the Regional Trial Court to issue a writ of preliminary injunction on the closure of Road Lot No. 3: The Supreme Court held that the Court of Appeals erred in reversing the RTC's denial of the application for a writ of preliminary injunction. The Court emphasized that a writ of preliminary injunction is an ancillary remedy that requires a full and comprehensive hearing where both parties present their evidence. The CA, by focusing solely on the evidence presented by Naga City and the respondents and disregarding the petitioners' evidence, misappreciated the nature of the remedy. The RTC correctly weighed the evidence, noting that the tax map and claims of customary use were insufficient to overcome BMC's ownership evidenced by its Certificate of Title (TCT) No. 13693 and the City Engineer's certification that Road Lot No. 3 was not among the city's inventory of roads. The Court reiterated that for a writ of preliminary injunction to be granted, the applicant must show a clear and unmistakable right, a material and substantial invasion of that right, an urgent need to prevent irreparable injury, and the absence of other adequate remedies. The respondents failed to establish these requisites. On Whether respondents established a clear and unmistakable right to utilize Road Lot No. 3 as a public road: The Supreme Court found that the respondents failed to establish prima facie proof of their clear legal right to utilize Road Lot No. 3. While Naga City presented a tax mapping control roll and identification map, and witnesses testified to the public nature of the road, this was rebutted by the Department of Health's Certificate of Title (TCT) No. 13693, which covered the entire BMC compound, including Road Lot No. 3. Furthermore, a certification from the City Engineer of Naga City explicitly stated that the road was not included in the list of city roads. The Court clarified that a clear legal right must be founded in or granted by law, and any doubt or dispute on the asserted right precludes the grant of preliminary injunctive relief. Customary use, without more, does not ripen into a legal right. Therefore, the unsubstantiated claims of Naga City and the respondents could not prevail over the DOH's title and the City Engineer's certification.
Main Doctrine
The Court of Appeals erred in directing the Regional Trial Court to issue a writ of preliminary injunction on the closure of Road Lot No. 3, as the respondents failed to establish prima facie proof of their clear legal right to utilize the road, which was rebutted by the petitioners' certificate of title and the City Engineer's certification.