G.R. No. 203806 , February 10, 2020
Municipality of Famy, Laguna, Petitioner, vs. Municipality of Siniloan, Laguna, Respondent.

FACTS

The Municipality of Famy and the Municipality of Siniloan are public corporations engaged in a boundary dispute over Barangays Kapatalan and Liyang. Historically, Famy was part of Siniloan but became a separate entity in 1909. The Provincial Board of Laguna rendered a Decision on March 26, 1962, ruling that Siniloan had jurisdiction over the barangays. In 2001, an elementary school was transferred to Barangay Kapatalan under Famy’s jurisdiction, and its barangay officials were elected under Famy’s authority. Siniloan sought to implement the 1962 Decision. The Sangguniang Panlalawigan of Laguna, in Resolutions No. 498, s. 2005 and No. 88, s. 2006, sustained Famy’s position, finding the 1962 Decision unexecutable for lack of metes and bounds and noting Siniloan’s abandonment of its claim. Siniloan filed a Petition for Certiorari and Prohibition before the Regional Trial Court (RTC), which granted a writ of preliminary injunction to restrain the implementation of the Sangguniang Panlalawigan’s resolutions and to enjoin Famy from intruding into the territorial jurisdiction of Siniloan over the barangays. The RTC denied Famy’s Motion for Reconsideration. The Court of Appeals affirmed the RTC’s Orders. Famy filed a Petition for Review on Certiorari before the Supreme Court.

ISSUE

Whether or not the Court of Appeals erred in affirming the Regional Trial Court’s issuance of a writ of preliminary injunction in favor of the Municipality of Siniloan.

RULING

The Supreme Court denied the Petition for lack of merit. It held that a writ of preliminary injunction is an ancillary and interlocutory order, temporary in nature, and subject to the final disposition of the principal action. Its issuance is within the discretion of the trial court and will not be interfered with by appellate courts in the absence of grave abuse of that discretion. The Court found that the RTC did not commit grave abuse of discretion. Siniloan established a clear and unmistakable right to the injunctive relief, as the implementation of the Sangguniang Panlalawigan’s resolutions would cause disorder in its governance over the barangays and reduce its internal revenue allotment. The injunctive relief was necessary to preserve the status quo and prevent serious and irreparable damage to Siniloan pending the resolution of the main petition. The issuance of the writ did not constitute a judgment on the merits of the case.