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MUNICIPALITY OF FAMY v. MUNICIPALITY OF SINILOAN

FACTS:

The case involves a boundary dispute between the Municipality of Famy and the Municipality of Siniloan in Laguna, two public corporations existing under Philippine law. Over a century ago, Famy was incorporated into Siniloan but later separated and became another entity. A boundary dispute arose between the two municipalities over two barangays, Kapatalan and Liyang. The Provincial Board of Laguna rendered a decision in 1962 ruling that Siniloan had jurisdiction over the barangays.

In 2001, an elementary school in Famy was transferred to Barangay Kapatalan, leading to Famy asserting jurisdiction over the barangay and its officials being elected under Famy's authority. Siniloan Vice Mayor Robelio J. Acoba sought the implementation of the 1962 decision and filed a petition to revive judgment before the Sangguniang Panlalawigan of Laguna.

Famy opposed Siniloan's petition and presented an earlier 1942 decision where Famy was granted jurisdiction over the disputed barangays. The Sangguniang Panlalawigan ruled in favor of Famy, stating that the 1962 decision lacked specificity on the territories of the municipalities and that Siniloan had abandoned its claim over Barangay Kapatalan.

Siniloan filed a petition for certiorari and prohibition before the Regional Trial Court, seeking a temporary restraining order and a writ of preliminary injunction. The trial court granted the writ of preliminary injunction, restraining the Sangguniang Panlalawigan from implementing its resolutions and restraining Famy from intruding into Siniloan's jurisdiction.

Famy filed a motion for reconsideration, which was subsequently denied by the trial court.

The petitioner, Famy, filed a Petition for Certiorari before the Court of Appeals seeking to annul the Regional Trial Court's Orders. Famy argued that the trial court erred in issuing the injunctive relief, as the writ cannot be issued incidental to a petition for prohibition. Famy also claimed that the conditions for issuing the writ were not fulfilled and that the trial court effectively resolved the case on the merits by issuing the writ. The respondent, Siniloan, countered that the writ was properly issued and within the trial court's discretion. The Court of Appeals upheld the trial court's orders, ruling that the writ of preliminary injunction was correctly issued as the Sangguniang Panlalawigan Resolutions would cause disorder to Siniloan's governance over the two barangays and invade its clear and unmistakable right. Famy's motion for reconsideration was denied, and they filed a Petition for Review for Certiorari against Siniloan. The Supreme Court gave due course to the petition and ordered the parties to submit their memoranda.

ISSUES:

  1. The lone issue in this case is whether or not the Court of Appeals erred in affirming the Regional Trial Court's issuance of a writ of preliminary injunction in favor of the respondent Municipality of Siniloan.

  2. Whether or not the Regional Trial Court committed grave abuse of discretion in issuing the writ of preliminary injunction.

  3. Whether or not the respondent sufficiently alleged and substantiated its clear legal right sought to be protected through the writ of preliminary injunction.

  4. Whether or not the petitioner's actuations in questioning the finality of the March 26, 1962 Decision are relevant in determining the issuance of the preliminary injunction.

  5. Whether or not the Court of Appeals erred in granting the petition for the issuance of a writ of preliminary mandatory injunction.

  6. Whether or not the Court of Appeals erred in ordering the Regional Trial Court to proceed with trial and resolve the Petition in Civil Case No. S-1013.

RULING:

  1. The Supreme Court denies the Petition for lack of merit.

  2. The Regional Trial Court did not commit grave abuse of discretion in issuing the writ of preliminary injunction.

  3. The respondent sufficiently alleged and substantiated its clear legal right sought to be protected through the writ of preliminary injunction. The respondent showed that it had in its favor a prior decision declaring its jurisdiction over the barangays in question, and it stood to suffer irreparable injury through the implementation of the Sangguniang Panlalawigan Resolutions.

  4. The determination of whether the March 26, 1962 Decision had attained finality is not relevant in determining the issuance of the preliminary injunction.

  5. The Court affirmed the Decision and Resolution of the Court of Appeals. It directed the Regional Trial Court to proceed with trial and resolve the Petition in Civil Case No. S-1013.

PRINCIPLES:

  • A preliminary injunction is an order granted at any stage of an action or proceeding prior to the judgment or final order, requiring a party to refrain from a particular act or requiring the performance of a particular act. It is an ancillary and interlocutory order issued based on an impartial determination of the context of both parties. Preliminary injunction may either be prohibitory or mandatory and is subject to the final disposition of the principal action.

  • For a writ of preliminary injunction to be issued, the following must be proven: (1) the applicant must have a clear and unmistakable right to be protected; (2) there is a material and substantial invasion of such right; (3) there is an urgent need for the writ to prevent irreparable injury to the applicant; and (4) no other ordinary, speedy, and adequate remedy exists to prevent the infliction of irreparable injury.

  • Courts are given wide discretion in granting a writ of preliminary injunction, but this discretion must be exercised with caution and within limits.

  • The court has discretion to issue a preliminary injunction, but this discretion is not unlimited and must be exercised with great caution. The court should not intervene in the exercise of discretion in injunctive matters in the absence of grave abuse of discretion.

  • Injunction should not be issued if there is no clear legal right materially and substantially breached from a prima facie evaluation of the evidence of the complainant.

  • Parties seeking injunction must present evidence to demonstrate their justification for the relief pending final judgment. Prima facie evidence suffices and the applicant is only required to show that he has an ostensible right to the final relief prayed for in his complaint.

  • A preliminary injunction is issued to preserve the status quo, the last actual, peaceful, and uncontested status that precedes the actual controversy.

  • The Court of Appeals has the authority to grant a petition for the issuance of a writ of preliminary mandatory injunction.

  • The Regional Trial Court is mandated to proceed with trial and resolve the petition before it.