G.R. No. 145328 March 23, 2006
EDUARDO F. HERNANDEZ, ET AL., and HON. FRANCISCO B. IBAY, petitioners, vs. NATIONAL POWER CORPORATION, respondent.

FACTS

Petitioners, residents of Dasmariñas Village, sought to enjoin the National Power Corporation (NAPOCOR) from energizing its 230 KV Sucat-Araneta-Balintawak power transmission line, which passed near their homes. They alleged that exposure to electromagnetic fields from the high-tension cables posed serious health risks, including cancer and leukemia. After failed negotiations with NAPOCOR, which offered options including a costly rerouting, petitioners filed a complaint for damages with a prayer for a preliminary injunction. The Regional Trial Court (RTC) granted a temporary restraining order (TRO) and subsequently a writ of preliminary injunction, enjoining NAPOCOR from energizing the line.
NAPOCOR filed a petition for certiorari with the Court of Appeals, arguing that the RTC had no jurisdiction to issue the injunction pursuant to Presidential Decree No. 1818, which prohibits courts from issuing restraining orders or injunctions in cases involving government infrastructure projects. The Court of Appeals reversed the RTC, ruling that the injunction was issued in violation of P.D. No. 1818. Petitioners elevated the case to the Supreme Court.

ISSUE

Whether the Regional Trial Court acted without jurisdiction or with grave abuse of discretion in issuing the writ of preliminary injunction against NAPOCOR’s power transmission project.

RULING

The Supreme Court granted the petition and reinstated the RTC’s order. The Court clarified that the prohibition under P.D. No. 1818 against injunctions is not absolute. It applies only to the issuance of injunctions against administrative acts involving facts or the exercise of discretion in technical cases. The prohibition does not extend to cases that involve pure questions of law. Here, the petitioners’ action was fundamentally anchored on the alleged violation of their constitutional right to health, which raises a justiciable legal question. The Court emphasized that when an injunction is sought to prevent a perceived threat to constitutional rights, such as the right to health, it falls outside the scope of the technical and factual controversies that P.D. No. 1818 seeks to insulate from judicial interference. Therefore, the RTC had jurisdiction to hear the application for injunction and did not commit grave abuse of discretion in issuing the writ to preserve the status quo and prevent alleged imminent danger pending a full trial on the merits. The case was remanded to the RTC for further proceedings.