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PLACIDO O. URBANES v. CA

FACTS:

This case involves a petition for review seeking to annul and set aside the decision of the Court of Appeals. The petitioner, Placido O. Urbanes, Jr., is the owner and operator of the Catalina Security Agency (CATALINA), which was awarded a contract to provide security services to the Social Security System (SSS) through a public bidding in 1987. However, the contract was later awarded to Bolinao Security and Investigation Services. CATALINA filed a case before the Regional Trial Court (RTC) to enjoin the award of the contract to Bolinao. The trial court issued a writ of preliminary injunction in favor of CATALINA. The SSS filed a petition for certiorari before the Court of Appeals, but it was dismissed due to procedural grounds. A compromise agreement was then forged between CATALINA and SSS, allowing CATALINA to continue providing security services while a new public bidding is conducted. The SSS conducted a new bidding and awarded the contract to Jaguar Security and Investigation Services, Inc. (JAGUAR). CATALINA filed an action for damages and injunction, claiming fraud and arbitrariness in the evaluation of bids. The trial court granted a writ of preliminary injunction in favor of CATALINA. The SSS filed a petition for certiorari before the Court of Appeals, seeking to nullify the orders of the trial court. The Court of Appeals granted the petition, nullifying the orders and ordering the dismissal of the case pending before the trial court. CATALINA filed this petition for review, arguing that the Court of Appeals exceeded its jurisdiction in ordering the dismissal of the case and in reviewing the findings of the trial court.

ISSUES:

  1. Whether the Court of Appeals exceeded its jurisdiction in ordering the dismissal of Civil Case No. Q-94-20557.

  2. Whether the Court of Appeals exceeded its jurisdiction in reviewing the findings of the lower court.

  3. Whether the Court of Appeals erred in not finding that the petitioner had presented prima facie evidence of irregularities in the bidding which justified the issuance of the preliminary injunction.

  4. Whether or not the trial court committed an act diametrically opposed to the time-honored legal principles in the issuance of the ancillary writ of preliminary injunction.

RULING:

  1. The Court of Appeals exceeded its jurisdiction in dismissing the main action for damages and injunction and in delving into the facts and merits of the main case. Certiorari cannot be used to correct erroneous conclusions of fact or law, and questions of fact are beyond the scope of a petition for certiorari. The authority of the Court of Appeals was limited to ruling on whether the trial court committed grave abuse of discretion in issuing the preliminary injunction, and it was not within its competence to decide the main case for damages and injunction.

  2. The trial court did not commit any act that was diametrically opposed to the time-honored legal principles. The issuance of the questioned writ of preliminary injunction was well-supported by sufficient evidence presented by the petitioner during the hearing held for that purpose. The trial court's evaluation of the evidence presented by both contending parties led the said court to hold that justice and equity would be better served if the status quo is preserved until a final determination of the merits of the pending case for damages and injunction is laid down. The Court of Appeals erred in reversing the trial court's findings and conclusions of fact and ruling that the trial court acted with grave abuse of discretion amounting to lack or excess of jurisdiction in issuing the writ of preliminary injunction. The case is remanded to the trial court for further proceedings.

PRINCIPLES:

  • A preliminary injunction is an order granted at any stage of an action, requiring a party or a court, agency, or person to refrain from a particular act or acts.

  • A permanent injunction is granted after the trial of the action if it appears that the applicant is entitled to have the act or acts complained of permanently enjoined.

  • The main action for injunction seeks a judgment embodying a final injunction, which is distinct from the provisional remedy of preliminary injunction.

  • The evidence submitted during the hearing on an application for a writ of preliminary injunction is not conclusive or complete, as only a "sampling" is needed to justify the preliminary injunction pending the decision on the merits. The findings of fact and opinion of a court when issuing the writ of preliminary injunction are interlocutory in nature and may be subject to change during the trial on the merits.

  • Certiorari cannot be used to correct erroneous conclusions of fact or law, and questions of fact are beyond the scope of a petition for certiorari. Appeals are the proper recourse to review errors in judgment.

  • The issuance of the writ of preliminary injunction as an ancillary or preventive remedy to secure the right of a party in a pending case rests upon the sound discretion of the trial court. The exercise of sound judicial discretion by the trial court in injunctive matters must not be interfered with except when there is manifest abuse. Rule 58, Section 7 of the Rules of Court gives generous latitude to the trial courts in this regard.

  • There is no grave abuse of discretion in the issuance of a writ of preliminary injunction where a party was not deprived of its day in court, as long as it was heard and had exhaustively presented all its arguments and defenses.

  • The Court of Appeals overstepped the bounds of its jurisdiction and authority by dismissing the main case before it could be heard by the trial court, even if there was grave abuse of discretion in the issuance of the writ of preliminary injunction. The nullification of the writ of preliminary injunction does not automatically lead to the dismissal of the main case.