GR 136114; (January, 2004) (Digest)
G.R. No. 136114; January 22, 2004
LANDBANK OF THE PHILIPPINES, Petitioner, vs. CONTINENTAL WATCHMAN AGENCY INCORPORATED AND THE COURT OF APPEALS, Respondents.
FACTS
Land Bank of the Philippines (LBP) published an invitation for security agencies to pre-qualify for a public bidding. Continental Watchman Agency Inc. (CWAI) participated and emerged as the lowest bidder for three areas. However, LBP’s Bid Committee disqualified CWAI, citing that its bid price was below the industry-prescribed monthly salary and that it violated a bid bulletin requiring the inclusion of night differential pay. CWAI’s motion for reconsideration was denied.
Consequently, CWAI filed a petition for injunction with damages and a prayer for a preliminary mandatory injunction before the Regional Trial Court (RTC). After conducting hearings where both parties presented evidence and arguments, the RTC issued an order granting the writ of preliminary injunction upon CWAI’s posting of a bond. The injunction directed LBP to cease from awarding the contracts for the disputed areas. LBP filed a petition for certiorari with the Court of Appeals, alleging the RTC committed grave abuse of discretion, but the appellate court dismissed the petition.
ISSUE
Did the Regional Trial Court commit grave abuse of discretion in issuing the writ of preliminary injunction?
RULING
No, the RTC did not commit grave abuse of discretion. The Supreme Court affirmed the Court of Appeals’ decision, emphasizing the nature of a certiorari petition and the discretion afforded to trial courts in issuing preliminary injunctions. A writ of certiorari under Rule 65 corrects errors of jurisdiction, not errors of judgment. Grave abuse of discretion implies a capricious, whimsical, or arbitrary exercise of power equivalent to lack of jurisdiction.
The legal logic rests on the procedural conduct of the RTC. The court meticulously followed Section 4, Rule 58 of the Rules of Civil Procedure by holding a hearing where both LBP and CWAI were given ample opportunity to present their evidence and arguments for and against the injunction. Since LBP was not deprived of its day in court and was fully heard, the RTC’s assessment of the requirements for a preliminary injunction—such as a clear right to be protected and the possibility of irreparable injury—falls within its sound discretion. The issuance, based on an evaluation of the facts and arguments presented, constitutes a proper exercise of judicial discretion, not a jurisdictional error. Therefore, any perceived error in the RTC’s factual or legal appreciation is merely an error of judgment, correctible by appeal, not by certiorari.