G.R. Nos. 115786-87; February 5, 1996
PHILIPPINE PORTS AUTHORITY and MANILA FLOATING SILO CORPORATION, petitioners, vs. THE HONORABLE COURT OF APPEALS, et al., respondents.

FACTS

The Philippine Ports Authority (PPA) entered into a contract with Manila Floating Silo Corporation (MAFSICOR) for the establishment of floating bulk terminal facilities at the South Harbor of the Port of Manila. This contract was challenged by several parties, including Marina Port Services, Inc. (now Asian Terminals, Inc.), which held existing contracts with PPA for integrated cargo handling services. The challengers filed separate complaints in the Regional Trial Court of Manila, seeking to enjoin the implementation of the PPA-MAFSICOR contract. The Court of Appeals subsequently issued a writ of preliminary injunction that effectively enjoined the said implementation.
Petitioners PPA and MAFSICOR assailed the issuance of the injunction, invoking Presidential Decree No. 1818. This decree explicitly prohibits courts from issuing restraining orders or preliminary injunctions in cases involving government infrastructure or natural resource development projects, which include public utilities for the transport of goods and stevedoring and arrastre contracts. Petitioners argued that the floating bulk terminal project falls under this protective mantle, making the injunction issued by the Court of Appeals void for lack of jurisdiction.

ISSUE

Whether the Court of Appeals acted without jurisdiction or with grave abuse of discretion in issuing a writ of preliminary injunction against the implementation of the PPA-MAFSICOR contract, in light of the prohibition under P.D. No. 1818.

RULING

The Supreme Court ruled in favor of the petitioners and set aside the injunction. The legal logic is anchored on the clear and mandatory language of P.D. No. 1818, which strips courts of jurisdiction to issue injunctive relief in specified cases to prevent disruption of critical government projects. The Court examined the nature of the PPA-MAFSICOR contract for floating bulk terminal facilities. It determined that the contract pertains to the operation of a public utility for the transport of commodities—specifically, the handling and storage of bulk grains—within a government port. This squarely falls within the enumeration of projects covered by the decree, which includes “stevedoring and arrastre contracts” and “public utilities for the transport of goods or commodities.”
The Court emphasized that the prohibition under P.D. No. 1818 is jurisdictional. Once a project is covered by the decree, any court that issues an injunction against it acts without authority. The purpose of the law is to shield essential economic development projects from legal delays. Since the floating terminal is integral to port operations and the government’s economic development effort, the Court of Appeals had no power to enjoin it. Consequently, the issuance of the writ of preliminary injunction was a grave abuse of discretion amounting to lack of jurisdiction, and the same was declared null and void.