G.R. No. 122241 July 30, 1996
BOARD OF OPTOMETRY, et al., petitioners, vs. HON. ANGEL B. COLET, et al., respondents.

FACTS

Private respondents, including Acebedo Optical Company and several optometrist associations, filed a petition for declaratory relief and prohibition with the Regional Trial Court (RTC) of Manila. They sought to declare Republic Act No. 8050 , the Revised Optometry Law of 1995, null and void on constitutional grounds, alleging defects in the legislative process, undue delegation of legislative power, violations of due process, and suppression of free speech. They also prayed for a writ of preliminary injunction to restrain the law’s implementation.
The RTC, presided by Judge Angel V. Colet, issued a temporary restraining order and, after a hearing, granted the application for a writ of preliminary injunction on August 25, 1995. The order enjoined the petitioners—government agencies tasked with enforcing the law—from implementing R.A. No. 8050 or any regulations issued under it. The government agencies then filed the instant petition for certiorari before the Supreme Court, seeking to annul the RTC’s order for having been issued with grave abuse of discretion.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in granting the writ of preliminary injunction against the implementation of R.A. No. 8050 .

RULING

Yes, the Supreme Court ruled that the RTC committed grave abuse of discretion. The legal logic is anchored on the principle that a preliminary injunction is an extraordinary remedy that should not issue to restrain the implementation of a statute absent a clear, unmistakable, and unequivocal demonstration of its constitutional invalidity. The Court emphasized the presumption of constitutionality that every law enjoys. The private respondents’ allegations of constitutional defects—such as procedural flaws in the law’s passage, vagueness, and undue delegation—were deemed to be substantial challenges that required a thorough judicial examination on the merits. However, for the purpose of issuing a preliminary injunction, these allegations alone, without a clear showing of the law’s patent nullity, were insufficient to overcome the presumption of validity.
Furthermore, the Court found that the issuance of the injunction effectively suspended the operation of a statute, which is a legislative act, based merely on the private respondents’ unproven assertions. This constituted a premature adjudication on the law’s constitutionality. The balance of convenience also favored the government, as public interest in the enforcement of a regulatory law designed to upgrade the optometry profession outweighed the private commercial interests asserted by the respondents. Consequently, the Supreme Court annulled the RTC’s orders and directed the dismissal of the civil case for declaratory relief, holding that the trial court exceeded its jurisdiction by paralyzing a statute through an injunction without a conclusive showing of its invalidity.