G.R. No. L-25757 and L-25780 December 28, 1970.
JOSE S. RICO, petitioner, vs. HON. COURT OF APPEALS, HON. JESUS P. MORFE, Judge of the Court of First Instance of Manila and ALCANTARA and SONS, INC., respondents. and THE EXECUTIVE SECRETARY, THE SECRETARY OF AGRICULTURE AND NATURAL RESOURCES, and THE DIRECTOR OF FORESTRY, petitioners, vs. HON. COURT OF APPEALS, HON. JESUS P. MORFE, Judge of the Court of First Instance of Manila, and ALCANTARA and SONS, INC., respondents.

FACTS

The controversy stems from Civil Case No. 59000 before the Court of First Instance of Manila, Branch XIII, presided by Judge Jesus P. Morfe. Respondent Alcantara and Sons, Inc. (ALSONS), holder of a timber license, filed a petition for certiorari, prohibition, and mandamus with preliminary injunction against public officials (the Executive Secretary, Secretary of Agriculture and Natural Resources, and Acting Director of Forestry) and private petitioner Jose S. Rico. ALSONS sought to set aside a decision by the Acting Director of Forestry, affirmed by the Secretary and the Executive Secretary, which established a new common boundary line between ALSONS’s and Rico’s adjacent forest concessions, transferring a 529-hectare tract to Rico’s area. ALSONS claimed the decision was rendered without a prior investigation as required by Forestry Administrative Order No. 6-2. The trial court issued a writ of preliminary injunction restraining the enforcement of the administrative decision and Rico from logging in the disputed area. Rico and the government officials moved for reconsideration, which was denied. They then filed a petition for certiorari, prohibition, and mandamus with the Court of Appeals (CA-G.R. No. 36772-R), arguing the trial court lacked jurisdiction as the matter was purely administrative and beyond judicial review. The Court of Appeals initially issued a preliminary injunction halting the trial court proceedings but later denied the petition and dissolved its own injunction. Rico subsequently commenced logging in the disputed area, interpreting the appellate court’s injunction as lifting the trial court’s restraint. ALSONS filed an urgent motion in the trial court to stop the export of these logs. The trial court then issued orders: one directing the Forestry Director to explain why he should not be punished for contempt for allowing the export, another ordering Rico to explain why he should not be punished for contempt for logging, and a third ordering the confiscation of the logs cut by Rico. These orders are the subject of the present petitions to the Supreme Court.

ISSUE

Whether the Court of First Instance of Manila acted without or in excess of jurisdiction and/or with grave abuse of discretion in issuing the contested orders in Civil Case No. 59000, specifically the orders (1) directing the Director of Forestry to show cause why he should not be punished for contempt, (2) directing Jose S. Rico to show cause why he should not be punished for contempt, and (3) ordering the confiscation of logs cut by Rico from the disputed area.

RULING

The Supreme Court denied the petitions. The Court held that the trial court did not act without jurisdiction or with grave abuse of discretion. The trial court had acquired jurisdiction over the case and the parties through ALSONS’s petition for certiorari, which alleged grave abuse of discretion by the administrative officials. The propriety of the trial court’s assumption of jurisdiction and its grant of a preliminary injunction was deemed already settled by the Court of Appeals’ decision in CA-G.R. No. 36772-R, which denied the petition to annul those very orders. The Supreme Court found no reason to disturb this conclusion. Regarding the contempt charges, the Court ruled that the trial court had the authority to initiate them based on reports that its injunction order had been violated. The fact that the alleged violations occurred after the Court of Appeals had issued its own preliminary injunction did not deprive the trial court of jurisdiction to inquire into possible contempt of its own orders. The trial court’s orders were merely preliminary steps to determine whether contempt was committed, not final punishments. The Supreme Court also dissolved its own preliminary injunction, except the part relating to the contempt charges in the lower court against Rico and the counsel for the Director of Forestry, which was made final. A motion by ALSONS to declare Rico in contempt of the Supreme Court was found to be without basis. Costs were imposed against petitioner Rico.