View full case

MID-ISLANDS POWER GENERATION CORPORATION v. CA

FACTS:

The case involves a dispute between Power One Corporation and Islands Grid Corporation against Mid-Islands Power Generation Corporation and MindoroTech Corporation regarding the operation and management of the Calapan Diesel Power Plant. Power One and Islands Grid contended that Mid-Islands Power and MindoroTech should be prevented from performing their obligations under the Energy Supply Agreement (ESA) and Revised Memorandum of Agreement (MOA) due to alleged violations and failure to fulfill certain conditions. On the other hand, Mid-Islands Power and MindoroTech argued that they should be allowed to fulfill their lawful obligations under the ESA and Revised MOA as the interests, rights, and obligations of the respondents had already been transferred to them. Temporary restraining orders were issued by the Pasig City Regional Trial Court (RTC), granting Mid-Islands Power and MindoroTech's prayer for a preliminary injunction. However, the Calapan RTC also issued a separate preliminary mandatory injunction, ordering the return of the power plant's operation to ORMECO (Oriental Mindoro Electric Cooperative) in the interest of public safety and to avoid a power crisis in the province of Oriental Mindoro.

The case involves a Complaint for injunction filed by MindoroTech Services Inc. and petitioner Mid-Islands Power Generation Corporation against respondents Power One Corporation, Islands Grid Network Philippines, Inc., David Tan, and Manuel Lauron. The dispute arose from an Electric Supply Agreement (ESA) entered into between Oriental Mindoro Electric Cooperative, Inc. (ORMECO) and Power One, wherein Power One was authorized to install and operate an electric generating facility in Oriental Mindoro. Power One proposed a joint venture called "Mid-Islands Power Generation Corporation" with potential partners, which would assume all the interests and obligations under the ESA. Various agreements were entered into, assigning rights and interests to Mid-Islands Power. However, disputes arose between Power One and Mid-Islands Power, with Power One alleging that Mid-Islands Power failed to fulfill its obligations under the agreements. Power One demanded specific performance from Mid-Islands Power, and claimed that their right to supply power to ORMECO and NPC had not taken effect. Power One informed ORMECO that the assignment of the ESA had not taken effect due to Mid-Islands Power's breach of obligations.

ISSUES:

  1. Whether or not the CA committed grave abuse of discretion in granting respondent Power One's Motion for Extension.

  2. Whether the deletion of the clause allowing an extension of time to file a Rule 65 petition prohibits the filing of a motion for extension.

  3. Whether motions for extension may be allowed, subject to the court's sound discretion, and only under exceptional and meritorious cases.

  4. Whether or not the Court of Appeals (CA) gravely abused its discretion in granting respondent Power One's Motion for Extension to file its Petition for Certiorari.

RULING:

  1. The Supreme Court did not provide the ruling for this case based on the given text.

  2. The deletion of the clause in Section 4, Rule 65 by A.M. No. 07-7-12-SC did not absolutely prohibit the filing of a motion for extension to file a Rule 65 petition. Motions for extension may still be allowed, subject to the court's sound discretion, and only under exceptional and meritorious cases.

  3. Relaxing the procedural rules would serve substantial justice and safeguard strong public interest in exceptional cases. Courts have the discretion whether or not to dismiss a case and may excuse a technical lapse to achieve the ends of justice rather than dispose of the case on technicality and cause grave injustice.

  4. The Supreme Court found no grave abuse of discretion attributable to the CA when it granted respondent Power One's Motion for Extension to file its Petition for Certiorari. The CA's approval of the motion was affirmed.

PRINCIPLES:

  • The territorial jurisdiction of a court is determined by where the acts sought to be restrained were committed.

  • Section 4, Rule 65 of the Rules of Court allows for the filing of a petition for certiorari within sixty (60) days from notice of the judgment, order, or resolution. However, there is no mention of whether or not an extension of time is still allowed under the amended rules.

  • Rules of procedure are mere tools designed to facilitate the attainment of justice and should not frustrate substantial justice.

  • Procedural technicalities may be relaxed in order to serve strong public interest and achieve the ends of justice.

  • Courts have the discretion whether to allow motions for extension to file a Rule 65 petition, subject to exceptional and meritorious cases.

  • The amendments under A.M. No. 07-7-12-SC, which set a 60-day period to file a Rule 65 petition, are meant to be implemented strictly.

  • Workload and resignation of a lawyer handling a case are insufficient reasons to justify the relaxation of procedural rules.

  • Strong public interest in a case may be a ground for the Court to exercise leniency in some situations.