GR 179492; (June, 2013) (Digest)
G.R. No. 179492; June 5, 2013
Republic of the Philippines, represented by ABUSAMA M. ALID, Officer-in-Charge, DEPARTMENT OF AGRICULTURE – REGIONAL FIELD UNIT XII (DA-RFU XII), Petitioner, vs. ABDULWAHAB A. BAYAO, OSMEÑA I. MONTAÑER, RAKMA B. BUISAN, HELEN M. ALVAREZ, NEILA P. LIMBA, ELIZABETH B. PUSTA, ANNA MAE A. SIDENO, UDTOG B. TABONG, JOHN S. KAMENZA, DELIA R. SUBALDO, DAYANG W. MACMOD, FLORENCE S. TAYUAN, in their own behalf and in behalf of the other officials and employees of DA-RFU XII, Respondents.
FACTS
The Department of Agriculture Regional Field Unit XII (DA-RFU XII) was directed by a Department Memorandum to transfer its regional seat of operations from Cotabato City to Koronadal City, pursuant to Executive Order No. 304. The respondents, officials and employees of DA-RFU XII, opposed the transfer, citing significant financial costs, lack of adequate facilities in Koronadal, and personal hardships. They filed a Complaint for Injunction with the Regional Trial Court (RTC) of Cotabato City, which granted a Writ of Preliminary Injunction, thereby enjoining the transfer.
Petitioner DA-RFU XII filed a Petition for Certiorari under Rule 65 directly with the Court of Appeals, challenging the RTC’s injunction order. The Court of Appeals dismissed the petition because the petitioner failed to first file a motion for reconsideration with the RTC, a procedural prerequisite. The petitioner then elevated the case to the Supreme Court via a Petition for Review on Certiorari under Rule 45.
ISSUE
The primary issue is whether the Court of Appeals correctly dismissed the Petition for Certiorari for failure to file a prior motion for reconsideration. The substantive issue is whether the trial court committed grave abuse of discretion in issuing the injunction against the implementation of an executive order and a department directive.
RULING
The Supreme Court granted the petition, reversed the Court of Appeals, and set aside the RTC’s injunction order. On procedure, the Court held that the filing of a motion for reconsideration is not an absolute prerequisite for certiorari where the order is a patent nullity, as in this case. The RTC’s injunction constituted a clear and blatant interference with a purely executive function.
On the merits, the Court ruled that the trial court committed grave abuse of discretion. The transfer of a government office pursuant to a valid executive order is an executive prerogative involving administrative discretion. The judiciary cannot inquire into the wisdom or expediency of such an act. The reasons raised by the employeesfinancial cost, inconvenience, and lack of facilitiespertain to the wisdom of the transfer, which is beyond judicial review. The injunction improperly restrained the execution of a lawful order and violated the principle of separation of powers. The Court emphasized that the remedy for aggrieved employees lies in appealing to executive authorities, not in seeking judicial injunction against the implementation of a valid executive directive.