G.R. No. L-78592 April 8, 1988
Municipality of Malolos, petitioner, vs. Libangang Malolos, Inc. represented by Ceferino Tiongson, Philippine Gamefowl Commission, respondents.

FACTS

Libangang Malolos, Inc. had operated the Malolos Cockpit Arena since 1914. Upon seeking renewal of its license for 1985, the Acting Mayor of Malolos denied the application based on Sangguniang Bayan resolutions declaring the cockpit’s location within a prohibited area. Invoking Section 4 of P.D. No. 1802-A, Libangang filed a complaint with the Philippine Gamefowl Commission (PGC), docketed as Case No. 59, seeking review of the municipal action and authority to resume operations. The PGC, in a Resolution dated January 31, 1985, allowed Libangang to resume operation.
Consequently, the Municipality of Malolos filed a Petition for Certiorari and Prohibition with the Regional Trial Court (RTC) of Malolos (Civil Case No. 7973-M) to enjoin the cockpit’s operation and to declare that the PGC had no jurisdiction to order its resumption. The PGC moved to dismiss the injunction case, arguing that under B.P. Blg. 129, exclusive appellate jurisdiction to review orders of quasi-judicial agencies like the PGC is vested in the Court of Appeals. The RTC initially dismissed the case but later, upon reconsideration by a different judge, set aside the dismissal and issued a writ of preliminary injunction against Libangang’s operations.

ISSUE

The primary issues were: (1) whether the RTC had jurisdiction to review the orders of the PGC, and (2) whether the Municipal Mayor’s authority to issue a cockpit license is subject to the review and supervision of the PGC.

RULING

The Supreme Court affirmed the Court of Appeals’ ruling that the RTC lacked jurisdiction. Under Section 9(3) of B.P. Blg. 129, the Court of Appeals possesses exclusive appellate jurisdiction over final judgments, decisions, orders, or awards of quasi-judicial agencies like the PGC. The PGC is statutorily at par with the RTC, and analogous to the rule that a court cannot interfere by injunction with the judgments of a court of concurrent jurisdiction, the RTC had no power to interfere with the PGC’s orders. The pendency of Case No. 59 before the PGC also precluded the RTC from assuming jurisdiction over the same controversy.
However, the Court reversed the appellate court on the second issue, holding that the Municipal Mayor’s authority to grant a license is not subject to PGC review and supervision. While P.D. No. 1802-A states that municipal licensing is “subject to [the Commission’s] review and supervision,” this clause was interpreted to mean that the municipality must act pursuant to the general rules and regulations promulgated by the PGC. The power to license remains a local function under the Local Government Code (B.P. Blg. 337). The PGC’s supervisory power is limited to ensuring that municipal actions comply with the Commission’s rules; it does not grant the PGC appellate authority to reverse or alter a municipal mayor’s discretionary licensing decision. The judgment was thus affirmed regarding jurisdiction but reversed concerning the extent of PGC supervisory power.