GR 132603; (September, 2000) (Digest)
G.R. No. 132603; September 18, 2000
ELPIDIO M. SALVA, ET AL., petitioners, vs. HON. ROBERTO L. MAKALINTAL, ET AL., respondents.
FACTS
Petitioners, officials and residents of Barangay San Rafael, Calaca, Batangas, filed a class suit before the Regional Trial Court (RTC) of Balayan, Batangas. They sought the annulment of Sangguniang Panlalawigan Ordinance No. 05 and Resolution No. 345, which abolished their barangay and merged it with Barangay Dacanlao, and COMELEC Resolution No. 2987, which scheduled the required plebiscite for February 28, 1998. Simultaneously, they filed an ex parte motion for a temporary restraining order (TRO) to enjoin the plebiscite. The RTC denied the motion, holding it lacked jurisdiction. It ruled that any action questioning a COMELEC act must be brought directly to the Supreme Court. Petitioners filed the instant petition directly with the Supreme Court, bypassing a motion for reconsideration due to the urgency of enjoining the imminent plebiscite.
ISSUE
Whether the Regional Trial Court has jurisdiction to enjoin the implementation of a COMELEC resolution scheduling a plebiscite, which resolution was issued pursuant to allegedly void local ordinances being challenged in a case pending before said trial court.
RULING
Yes, the RTC has jurisdiction. The Supreme Court granted the petition and set aside the RTC’s order. The legal logic is anchored on the nature of the COMELEC’s act. The issuance of Resolution No. 2987, which merely set the date and rules for the plebiscite, was a ministerial duty mandated by the Local Government Code once the local legislative bodies enacted the merger ordinance. The COMELEC did not exercise its quasi-judicial or adjudicatory powers; it performed an administrative, ministerial function incidental to its enforcement role.
Consequently, the validity of the COMELEC resolution is entirely dependent on the validity of the underlying ordinances. Since the RTC unquestionably has original jurisdiction to rule on the validity of the local ordinances (Ordinance No. 05 and Resolution No. 345) in the main action for annulment, it also possesses the ancillary jurisdiction to issue provisional reliefs, like a TRO or injunction, against the enforcement of the COMELEC resolution. To require petitioners to seek injunctive relief from the Supreme Court would result in multiplicity of suits and splitting a single cause of action, as the injunction issue is inextricably linked to the main case pending with the RTC. The trial court was thus ordered to proceed with the case and defer execution of the plebiscite results pending its final outcome.