Municipality of Famy, Laguna vs. Municipality of Siniloan, Laguna

A writ of preliminary injunction may be issued incidental to a petition for certiorari and prohibition when the applicant demonstrates by prima facie evidence: (1) a clear and unmistakable right in esse; (2) a material and substantial invasion of such right; (3) an urgent need to prevent irreparable injury; and (4) the absence of any ordinary, speedy, and adequate remedy, with courts exercising wide but limited discretion that will not be disturbed absent grave abuse thereof.

Famy was originally incorporated into Siniloan through Act No. 939 (1903) but was separated as a distinct municipality via Executive Order No. 72 (1909). This separation generated a boundary dispute over Barangays Kapatalan and Liyang. On March 26, 1962, the Provincial Board of Laguna rendered a decision declaring Siniloan's jurisdiction over the barangays. However, in 2001, an elementary school was transferred to Barangay Kapatalan under Famy's administration, and barangay officials were elected and recognized under Famy's authority.

• Historical Background: The municipalities of Famy and Siniloan are public corporations existing under Philippine law. Famy was originally incorporated into Siniloan through Act No. 939, series of 1903, but was separated as a distinct municipality through Executive Order No. 72, series of 1909. This separation generated a boundary dispute concerning jurisdiction over Barangays Kapatalan and Liyang.

• The 1962 Provincial Board Decision: On March 26, 1962, the Provincial Board of Laguna rendered a decision ruling that Siniloan had jurisdiction over the disputed barangays. Following this decision, Siniloan exercised governmental functions over the area, including the adjudication of criminal cases involving residents, acceptance of payment of real property taxes, registration of voters, and construction of infrastructure projects such as school buildings and barangay halls.

• The 2001 Shift and Sangguniang Panlalawigan Proceedings: In 2001, an elementary school was transferred to Barangay Kapatalan and was placed under Famy's jurisdiction, with barangay officials elected and declared under Famy's authority. This prompted Siniloan to file a Petition to Revive Judgment before the Sangguniang Panlalawigan to implement the 1962 Decision. Famy opposed, submitting a copy of a July 4, 1942 Provincial Board Decision allegedly granting Famy jurisdiction over the barangays.

• The Assailed Resolutions: The Sangguniang Panlalawigan issued Resolution No. 498, series of 2005, sustaining Famy's position. It found that the 1962 Decision could not be executed for lack of specified metes and bounds, noted that implementation would reduce Famy's population and land area below statutory requirements, and held that Siniloan abandoned its claim over Barangay Kapatalan by ceasing internal revenue allotment payments. Resolution No. 88, series of 2006, denied Siniloan's motion for reconsideration.

• RTC Injunctive Relief: Siniloan filed a Petition for Certiorari and Prohibition before the Regional Trial Court of Siniloan, Laguna (Branch 33), praying for a temporary restraining order and writ of preliminary injunction. The RTC issued the writ on February 20, 2008, restraining the Sangguniang Panlalawigan from implementing its Resolutions and enjoining Famy from exercising authority over the disputed barangays. The RTC found that Siniloan had continuously exercised dominion over the barangays based on the 1962 Decision, that taxes were being paid to Siniloan, and that implementation of the Resolutions would reduce Siniloan's internal revenue allotment.

• Availability of Injunctive Relief: Famy contended that the Court of Appeals erred in upholding the trial court's issuance of the writ of preliminary injunction incidental to a petition for prohibition, arguing that prohibition is unavailing to prevent enforcement of an erroneous decision and that injunctive relief is improper when sought merely as an incident to prohibition.

• Impropriety of Certiorari: Famy maintained that certiorari is not the proper remedy as it cannot substitute for a lost right to appeal, implying that Siniloan should have pursued other available remedies.

• Lack of Clear Right and Irreparable Injury: Famy argued that the implementation of the Sangguniang Panlalawigan Resolutions would not cause serious or irreparable damage because Siniloan failed to establish a clear, unmistakable right that was violated. It claimed that Siniloan failed to prove that the 1962 Decision was final and executory, noting that no copy was shown to have been received by Famy, which would have been the reckoning point for finality.

• Prescription: Famy asserted that even if the 1962 Decision had attained finality, it had prescribed in 1972, thereby extinguishing Siniloan's right long before the resolutions were issued.

• Government Recognition: Famy claimed that government recognition of the 1962 Decision does not suffice to show finality, as other government agencies had also acknowledged Famy's right to govern the contested barangays.

• Propriety of Injunctive Relief: Siniloan countered that the writ was properly issued and was solely within the trial court's discretion, arguing that preliminary injunction is an ancillary remedy available in certiorari and prohibition proceedings to preserve the status quo pending resolution of the principal action.

• Existence of Clear Right and Irreparable Injury: Siniloan argued that it possessed a clear legal right evidenced by the 1962 Provincial Board Decision, which it had continuously exercised through adjudication of criminal cases, collection of real property taxes, voter registration, and infrastructure projects. It posited that implementation of the Resolutions would cause irreparable injury through a considerable reduction of its internal revenue allotment and disruption of governance over residents who had been under its jurisdiction for decades.

• Falsity of Opposing Evidence: Siniloan asserted that Famy's resort to the Supreme Court was based on a falsified document, claiming that the Sangguniang Panlalawigan gave undue credence to a purported photocopy of an unsigned 1942 decision despite overwhelming evidence in Siniloan's favor. It argued that the Sangguniang Panlalawigan had no jurisdiction to overturn the 1962 Decision, which had long attained finality.

• Propriety of Preliminary Injunction Ancillary to Certiorari and Prohibition: Whether the Court of Appeals erred in affirming the Regional Trial Court's issuance of a writ of preliminary injunction incidental to a petition for certiorari and prohibition.

• Existence of Grave Abuse of Discretion: Whether the Regional Trial Court committed grave abuse of discretion in issuing the writ of preliminary injunction.

• Propriety of Preliminary Injunction Ancillary to Certiorari and Prohibition: The issuance of a writ of preliminary injunction incidental to a petition for certiorari and prohibition is proper. Preliminary injunction is an ancillary and interlocutory remedy, temporary in nature and subject to the final disposition of the principal action. It may be granted at any stage of an action prior to judgment to require a party to refrain from particular acts or to perform particular acts. Contrary to Famy's claim, the writ is not a judgment on the merits but a provisional remedy to preserve the status quo—the last actual, peaceful, and uncontested status preceding the controversy—pending final resolution of the case.

• Existence of Grave Abuse of Discretion: The Regional Trial Court did not commit grave abuse of discretion. Grave abuse of discretion is defined as the arbitrary or despotic exercise of power due to passion, prejudice, or personal hostility, or the whimsical, arbitrary, or capricious exercise of power that amounts to an evasion or refusal to perform a positive duty enjoined by law. Courts are given wide discretion in granting injunctive relief, which will not be disturbed on appeal in the absence of grave abuse.

• Satisfaction of Requisites for Injunction: Siniloan satisfied the four requisites for issuance of a writ of preliminary injunction: (1) it demonstrated a clear and unmistakable right in esse through the 1962 Provincial Board Decision and continuous exercise of jurisdiction over the disputed barangays, evidenced by criminal case adjudications, tax payments, voter registration, and infrastructure projects; (2) the Sangguniang Panlalawigan Resolutions constituted a material and substantial invasion of that right by transferring jurisdiction to Famy; (3) urgent need existed to prevent irreparable injury, specifically the reduction of internal revenue allotment and disruption of governmental functions; and (4) no other ordinary, speedy, and adequate remedy existed. Prima facie evidence suffices at the hearing for preliminary injunction; conclusive proof is not required as the issue of violation of rights will still be fully litigated in the main case.

• Preliminary Injunction as an Ancillary Remedy — A preliminary injunction is an order granted at any stage of an action or proceeding prior to judgment or final order, requiring a party or court to refrain from particular acts or to perform particular acts. It is ancillary, interlocutory, and temporary in nature, subject to the final disposition of the principal action. It preserves the status quo, defined as the last actual, peaceful, and uncontested status that precedes the actual controversy existing at the time of the filing of the case.

• Requisites for Issuance of Writ of Preliminary Injunction — For a writ of preliminary injunction to issue, the applicant must establish: (1) a clear and unmistakable right to be protected (a right in esse); (2) a material and substantial invasion of such right; (3) an urgent need for the writ to prevent irreparable injury to the applicant; and (4) the absence of any other ordinary, speedy, and adequate remedy to prevent the infliction of irreparable injury.

• Standard of Proof for Preliminary Injunction — At the hearing for the issuance of a writ of preliminary injunction, mere prima facie evidence is needed to establish the applicant's rights or interests in the subject matter of the main action. Complete and conclusive proof is not required, as the issue of whether there was a violation of rights will still be fully litigated in the main case. The applicant need only show an ostensible right to the final relief prayed for.

• Grave Abuse of Discretion — Grave abuse of discretion is the arbitrary or despotic exercise of power due to passion, prejudice, or personal hostility; or the whimsical, arbitrary, or capricious exercise of power that amounts to an evasion or a refusal to perform a positive duty enjoined by law or to act at all in contemplation of law. In the absence of grave abuse of discretion, appellate courts shall not intervene in the trial court's exercise of discretion in injunctive matters.

• "In the absence of grave abuse of discretion, this Court shall not intervene in the trial court's exercise of discretion in injunctive matters." — This passage establishes the limited scope of judicial review over trial court orders granting injunctive relief.

• "It is crystal clear that at the hearing for the issuance of a writ of preliminary injunction, mere prima facie evidence is needed to establish the applicant's rights or interests in the subject matter of the main action. It is not required that the applicant should conclusively show that there was a violation of his rights as this issue will still be fully litigated in the main case. Thus, an applicant for a writ is required only to show that he has an ostensible right to the final relief prayed for in his complaint." — This defines the quantum of evidence required for provisional injunctive relief.

• "Preliminary injunctions are issued to preserve the status quo, 'the last actual, peaceful, and uncontested status that precedes the actual controversy, that which is existing at the time of the filing of the case.'"

• Ong Lay Hin v. Court of Appeals, 752 Phil. 15 (2015) — Cited for the definition of grave abuse of discretion as the arbitrary or despotic exercise of power due to passion, prejudice, or personal hostility, or the whimsical, arbitrary, or capricious exercise of power that amounts to an evasion or refusal to perform a positive duty enjoined by law.

• Cortez-Estrada v. Heirs of Samut, 491 Phil. 458 (2005) — Cited for the principle that in the absence of grave abuse of discretion, the Supreme Court shall not intervene in the trial court's exercise of discretion in injunctive matters, and for the definition of status quo.

• Bicol Medical Center v. Botor, 819 Phil. 447 (2017) — Cited for the definition of preliminary injunction and the requisites for its issuance, including the standard that mere prima facie evidence suffices at the hearing for issuance.

• Spouses Nisce v. Equitable PCI Bank, 545 Phil. 138 (2007) — Cited for the requirement that litigants applying for injunctive relief must exhibit their present and unmistakable right to be protected, the violation of such right by the facts against which injunction is directed, and the special and paramount necessity for the writ to prevent serious damages.

• Rule 58, Section 1 of the Rules of Court — Defines preliminary injunction as an order granted at any stage of an action or proceeding prior to judgment or final order, requiring a party or court to refrain from particular acts (prohibitory) or to perform particular acts (mandatory).

• Rule 58, Section 3 of the Rules of Court — Enumerates the grounds for issuance of preliminary injunction: (a) the applicant is entitled to the relief demanded consisting in restraining commission or continuance of acts or requiring performance of acts; (b) commission, continuance or non-performance of acts during litigation would probably work injustice; or (c) a party is doing, threatening, or attempting to do acts probably in violation of the applicant's rights and tending to render judgment ineffectual.

Gesmundo, Zalameda, and Gaerlan, JJ., concur.