Soller v. Singson

R.A. No. 8975 prohibits lower courts from issuing only temporary restraining orders and writs of preliminary injunction against government infrastructure projects, but does not bar lower courts from rendering decisions on the merits granting permanent injunctions; the principal action for injunction is within the jurisdiction of the RTC as a civil case incapable of pecuniary estimation, and the ancillary remedy of preliminary injunction does not determine jurisdiction.

Petitioners are owners of parcels of land located near the Strong Republic Nautical Highway at Poblacion, Bansud, Oriental Mindoro. Respondents include officials of the Department of Public Works and Highways (DPWH) — Secretary Rogelio Singson and District Engineer Magtanggol Roldan — and King's Builders and Development Corporation together with its president, Engr. Elegio Malaluan, the contractor undertaking the elevation of the national highway. The statutory backdrop includes Presidential Decree No. 1818 and Republic Act No. 8975, both of which restrict the issuance of injunctive writs by lower courts against government infrastructure and natural resources development projects.

Petitioners Spouses Prudente D. Soller and Preciosa M. Soller, Raffy Telosa, and Gavino Manibo, Jr. are owners of parcels of land located near the Strong Republic Nautical Highway at Poblacion, Bansud, Oriental Mindoro. King's Builder and Development Corporation commenced an elevation project between kilometer 90 and 92 of the national highway near the Bansud River Bridge. According to petitioners, the elevation of the national highway to approximately one meter blocked and retained floodwaters naturally flowing from the nearby Bansud River and farm lands from the direction of the mountains of Conrazon, submerging houses and lands on the left side of the road, including their properties, and placing their safety in imminent danger.

Petitioners further alleged that the elevation impaired their use and enjoyment of their houses and properties, as pedestrians and vehicles alike had to negotiate a steep climb and descent in going to and from their properties. To address these concerns, petitioners filed a Complaint for Permanent Injunction and damages with a prayer for the issuance of a Temporary Restraining Order and/or Preliminary Injunction before the RTC of Pinamalayan, Oriental Mindoro, Branch 41.

Instead of filing an Answer, respondents Secretary Singson and Engr. Roldan filed a Motion to Dismiss, asserting that the issuance of injunctive writs was prohibited by Presidential Decree No. 1818 and that the doctrine of state immunity from suit applied. The RTC granted the Motion to Dismiss in its Resolution dated July 10, 2014, finding that it had no jurisdiction over the case under R.A. No. 8975. Petitioners' Motion for Reconsideration was denied in a Resolution dated November 18, 2014, prompting the elevation of the matter to the Supreme Court.

• Jurisdiction of the RTC: Petitioners insisted that the RTC has jurisdiction over the subject matter, arguing that their petition involves a pure question of law delving into the jurisdiction of the RTC over the case.
• Nature of the Action: Petitioners maintained that their complaint was one for injunction with a prayer for the issuance of a TRO and/or preliminary injunction, and that the principal action — not the ancillary remedy — should determine jurisdiction.

• Procedural Defect: The Office of the Solicitor General argued that the petition must be dismissed outright as it raises factual issues.
• Propriety of Dismissal: The OSG asserted that the dismissal of the case was proper because petitioners prayed for the issuance of a TRO in their complaint, which is prohibited under R.A. No. 8975.
• Statutory and Doctrinal Bars: Respondents Singson and Roldan argued that the issuance of injunctive writs is prohibited by Presidential Decree No. 1818 and that the doctrine of state immunity from suit applies.

• Jurisdiction: Whether the RTC has jurisdiction over a complaint for permanent injunction against a government infrastructure project, notwithstanding the prohibitions in R.A. No. 8975 and P.D. No. 1818.
• Scope of Statutory Prohibition: Whether R.A. No. 8975 prohibits lower courts from issuing permanent injunctions, or only temporary restraining orders and preliminary injunctions, against government infrastructure projects.

• Jurisdiction: Yes. The RTC has jurisdiction over the principal action for injunction, which is a civil case incapable of pecuniary estimation under Section 19 of Batas Pambansa Blg. 129; the ancillary remedy of preliminary injunction does not determine jurisdiction.
• Scope of Statutory Prohibition: No. R.A. No. 8975 prohibits lower courts from issuing only TROs and preliminary injunctions, not permanent injunctions granted after adjudication on the merits; statutes trenching on judicial power must be strictly construed.

• Jurisdiction: Jurisdiction is determined by the allegations in the complaint and the character of the relief sought. The allegations and reliefs prayed for in the complaint reveal that petitioners, as landowners surrounding the highway elevation project, sought to enjoin the construction or, if completed, to restore the affected portion to its original state. The principal action is one for injunction, which is within the jurisdiction of the RTC under Section 19 of Batas Pambansa Blg. 129, as a civil action incapable of pecuniary estimation. The principal action for injunction is distinct from the provisional or ancillary remedy of preliminary injunction, which cannot exist except as part of an independent action or proceeding. What is controlling for jurisdictional purposes is the principal action, not the ancillary remedy which is merely an incident thereto.

• Scope of Statutory Prohibition: Section 3 of R.A. No. 8975 expressly vests jurisdiction upon the Supreme Court — to the exclusion of all other courts — to issue TROs, preliminary injunctions, or preliminary mandatory injunctions against the government and its subdivisions in connection with specified government infrastructure projects. However, as clarified in Bases Conversion and Development Authority vs. Uy, the prohibition covers only temporary or preliminary restraining orders or writs, and not decisions on the merits granting permanent injunctions. Because these statutes trench on judicial power, they must be strictly construed. While lower courts are prohibited from issuing temporary or preliminary restraining orders pending adjudication, the statutes do not explicitly proscribe the issuance of a permanent injunction granted by a court of law arising from an adjudication on the merits. The RTC therefore erred in dismissing the complaint for lack of jurisdiction.

• Doctrine of jurisdiction determined by allegations in the complaint — Jurisdiction of the court is determined by the allegations in the complaint and the character of the relief sought, not by the ancillary remedies prayed for. The Court applied this doctrine by examining the complaint's allegations and concluding that the principal action was for injunction, an action incapable of pecuniary estimation within RTC jurisdiction, notwithstanding the prayer for TRO/preliminary injunction.

• Distinction between principal action and ancillary remedy — The principal action for injunction is distinct from the provisional or ancillary remedy of preliminary injunction, which cannot exist except as part of an independent action or proceeding. The Court relied on this distinction to hold that the controlling factor for jurisdiction is the principal action, not the ancillary remedy.

• Strict construction of statutes trenching on judicial power — Statutes that restrict judicial power, such as R.A. No. 8975 and P.D. No. 1818, must be strictly construed. The Court applied this principle to hold that the prohibition under R.A. No. 8975 covers only TROs and preliminary injunctions, not permanent injunctions rendered after adjudication on the merits.

• Relaxation of procedural rules in the interest of justice — When strict and rigid application of procedural rules would result in technicalities that frustrate rather than promote substantial justice, such rules must be eschewed. The Court invoked this doctrine to resolve the case on the merits despite petitioners' use of the wrong remedy (Rule 45 instead of Rule 65) and their violation of the doctrine of hierarchy of courts.

• "A perusal of these aforequoted provisions readily reveals that all courts, except this Court, are proscribed from issuing TROs and writs of preliminary injunction against the implementation or execution of specified government projects. Thus, the ambit of the prohibition covers only temporary or preliminary restraining orders or writs but NOT decisions on the merits granting permanent injunctions." — This passage, quoted from Bases Conversion and Development Authority vs. Uy, articulates the critical distinction between preliminary and permanent injunctions under R.A. No. 8975 and forms the ratio decidendi of the Court's ruling on the scope of the statutory prohibition.

• "In determining the jurisdiction of the RTC, what is controlling is the principal action, and not the ancilliary remedy which is merely an incident thereto." — This formulation crystallizes the doctrinal basis for the Court's jurisdictional ruling, establishing that the prayer for TRO/preliminary injunction does not oust the RTC of jurisdiction over the principal action for injunction.

• "Thus, when the strict and rigid application of procedural rules would result in technicalities that tend to frustrate rather than promote substantial justice, they must always be eschewed." — This passage states the Court's rationale for relaxing procedural rules to resolve the case on the merits despite the petitioners' procedural lapses.

• Bases Conversion and Development Authority vs. Uy, 537 Phil. 18 (2006) — Controlling precedent on the scope of R.A. No. 8975; the Court followed its ruling that the statutory prohibition covers only TROs and preliminary injunctions, not permanent injunctions granted on the merits.

• Philco Aero, Inc. vs. Secretary Tugade, G.R. No. 237486, July 3, 2019 — Recognized the remedy of resorting directly to the Supreme Court in cases covered under R.A. No. 8975, confirming that Section 3 explicitly excludes other courts from issuing injunctive writs.

• Development Bank of the Philippines vs. Judge Carpio, 805 Phil. 99 (2017) — Cited for the proposition that a dismissal based on lack of jurisdiction over the subject matter operates as a dismissal without prejudice and is not subject to appeal under Rule 41.

• Surviving Heirs of Alfredo R. Bautista vs. Lindo, 728 Phil. 630 (2014) — Cited for the established rule that jurisdiction is determined by the allegations in the complaint and the character of the relief sought.

• Evy Construction and Development Corporation vs. Valiant Roll Forming Sales Corporation, G.R. No. 207938, October 11, 2017 — Cited for the distinction between the principal action for injunction and the ancillary remedy of preliminary injunction.

• Section 3, Republic Act No. 8975 — Prohibits all courts, except the Supreme Court, from issuing TROs, preliminary injunctions, or preliminary mandatory injunctions against the government or its subdivisions to restrain specified acts related to national government projects, including acquisition, bidding, commencement, prosecution, execution, implementation, operation, termination, or rescission of such projects. The Court construed this provision strictly, holding that the prohibition covers only temporary or preliminary writs, not permanent injunctions rendered after adjudication on the merits.

• Section 19, Batas Pambansa Blg. 129 (as amended) — Vests Regional Trial Courts with exclusive original jurisdiction over all civil actions in which the subject of the litigation is incapable of pecuniary estimation. The Court applied this provision to hold that a complaint for injunction falls within RTC jurisdiction.

• Section 1, Rule 41 of the Rules of Court — Provides that an order dismissing an action without prejudice is not appealable, and the aggrieved party's remedy is to file an appropriate special civil action under Rule 65. The Court noted that petitioners availed of the wrong remedy by filing under Rule 45 instead of Rule 65.

• Presidential Decree No. 1818 — Prohibits courts from issuing restraining orders or preliminary injunctions in cases involving infrastructure and natural resources development projects of, and public utilities operated by, the government. Respondents invoked this decree as a ground for dismissal, but the Court resolved the case primarily under R.A. No. 8975.

Peralta, C.J. (Chairperson), Caguioa (Working Chairperson), Lazaro-Javier, and Lopez, JJ., concurred.