Soller v. Singson
REITERATIONFacts
The Antecedents: Petitioners, Spouses Soller and others, are owners of properties near the Strong Republic Nautical Highway in Bansud, Oriental Mindoro. They filed a complaint for Permanent Injunction and damages with a prayer for TRO/Preliminary Injunction against government officials (Secretary of DPWH, District Engineer) and a private corporation (King's Builders and Development Corporation) involved in an elevation project of the national highway. Petitioners alleged that the project, by raising the highway by one meter, blocked floodwaters from the Bansud River and farmlands, submerging their properties and impairing their use and enjoyment due to the steep incline and decline created. Procedural History: Respondents Secretary Singson and Engr. Roldan filed a Motion to Dismiss, arguing that injunctive writs are prohibited by P.D. No. 1818 and that the State's immunity from suit applies. The RTC granted the Motion to Dismiss, finding it had no jurisdiction based on R.A. No. 8975. The RTC's Resolution was dated July 10, 2014. Petitioners' Motion for Reconsideration was denied in a Resolution dated November 18, 2014. The Petition: Aggrieved, petitioners elevated the matter to the Supreme Court via an appeal by certiorari under Rule 45, assailing the RTC's dismissal orders. The Office of the Solicitor General (OSG) argued for dismissal, citing factual issues and the prayer for a TRO. Petitioners countered that the issue was purely of law concerning the RTC's jurisdiction.
Issue(s)
Whether the Regional Trial Court (RTC) has jurisdiction over a principal action for injunction involving a government infrastructure project, despite the prohibitions under R.A. No. 8975 and P.D. No. 1818. Whether the petition for certiorari under Rule 45 was the proper remedy, and whether the doctrine of hierarchy of courts was violated.
Ruling
The Supreme Court granted the petition, reversed and set aside the Resolutions of the RTC, and remanded the case to the RTC for further proceedings. The Court ruled that the RTC has jurisdiction over the principal action for injunction, and that the prohibition under R.A. No. 8975 and P.D. No. 1818 applies only to temporary or preliminary injunctive writs, not to the adjudication of the case on the merits.
Ratio Decidendi
On the Jurisdiction of the RTC over the Principal Action for Injunction: The Court held that the RTC has jurisdiction over the subject matter. It clarified that while R.A. No. 8975 and P.D. No. 1818 prohibit lower courts from issuing temporary restraining orders (TROs) or preliminary injunctions against government infrastructure projects, this prohibition does not extend to the adjudication of the case on the merits, including the issuance of a permanent injunction. The Court emphasized that the jurisdiction of a court is determined by the allegations in the complaint and the character of the relief sought. In this case, the principal action was for injunction, which falls under the exclusive original jurisdiction of the RTC over civil cases where the subject matter is incapable of pecuniary estimation, as conferred by Section 19 of Batas Pambansa Blg. 129. The prayer for a TRO or preliminary injunction is merely an ancillary remedy, and its prohibition does not divest the RTC of its jurisdiction over the main case. On the Proper Remedy and Hierarchy of Courts: The Court acknowledged that petitioners committed procedural errors by filing an appeal by certiorari under Rule 45 instead of a petition for certiorari under Rule 65, and by directly filing with the Supreme Court instead of the Court of Appeals, thus violating the doctrine of hierarchy of courts. However, the Court relaxed the strict application of procedural rules in the interest of substantial justice and equity. It cited numerous cases where procedural rules were set aside to prevent a miscarriage of justice. Therefore, in the exercise of its equity jurisdiction, the Court opted to resolve the case on the merits, considering the substantive issue of jurisdiction raised by the petitioners.
Main Doctrine
The Regional Trial Court (RTC) has jurisdiction over a principal action for injunction, even if it involves a government infrastructure project, as the prohibition under R.A. No. 8975 and P.D. No. 1818 pertains only to the issuance of temporary or preliminary injunctive writs, not to the adjudication of the case on the merits.