G.R. No. L-30135. February 21, 1980.
Braulio Sto. Domingo, Gaudencio Mapile, Pedro G. Tuason, Ponciano Rivera, Simon B. Reyes, Jr., petitioners, vs. Hon. Judge Walfrido de los Angeles and Eduardo San Pascual, respondents.

FACTS

Petitioner Simon B. Reyes, Jr., a police captain, was suspended by respondent Chief of Police Eduardo San Pascual for alleged insubordination. Reyes subsequently filed an administrative complaint against San Pascual for oppression and grave misconduct before the Police Commission (POLCOM). The POLCOM referred the complaint to the Local Board of Investigators of San Juan, Rizal, which initially recommended San Pascual’s preventive suspension. San Pascual then filed a civil case in the Court of First Instance, presided by respondent Judge Walfrido de los Angeles, against Mayor Sto. Domingo, the Board members, the POLCOM, and Reyes. He sought damages and a preliminary injunction to halt the administrative proceedings, challenging the constitutionality of the Police Act of 1966 (Republic Act No. 4864) and its conflict with the Decentralization Act (Republic Act No. 5185).
The respondent Judge granted the writ of preliminary injunction, enjoining all administrative actions against San Pascual. He reasoned that allowing the investigation to proceed under a potentially unconstitutional statute would violate San Pascual’s basic rights and subject him to humiliation. Petitioners, the municipal officials and Reyes, filed this certiorari and prohibition case, alleging grave abuse of discretion. This Court initially issued a restraining order against the Judge’s injunction, which had the effect of suspending San Pascual from his post.

ISSUE

Whether the respondent Judge committed grave abuse of discretion in issuing a writ of preliminary injunction to halt the administrative investigation against Chief of Police San Pascual.

RULING

Yes, the respondent Judge committed grave abuse of discretion. The Supreme Court nullified the injunctive orders. The legal logic is clear: a court cannot enjoin an administrative investigation merely on grounds of an alleged constitutional infirmity in the governing statute, especially when no actual conflict of laws has been demonstrated. The presumption of constitutionality must prevail until a statute is formally declared invalid. Injunction is an extraordinary remedy requiring a clear and unmistakable right; it cannot be invoked on speculative grounds like potential embarrassment or a hypothetical declaration of unconstitutionality.
Furthermore, the Court found no conflict between the Police Act of 1966 and the Decentralization Act. The Police Act is a special law governing the discipline of police forces, granting the POLCOM and local boards specific investigative and disciplinary powers. The Decentralization Act is a general law on local government. Under statutory construction, a special law prevails over a general law. The administrative process, including preventive suspension, must be allowed to run its course. Judicial interference via injunction at the investigatory stage undermines administrative authority and public interest in maintaining police discipline. The due process clause does not shield a public officer from a lawful investigative process. The proper recourse for San Pascual was to exhaust administrative remedies and raise constitutional questions only upon a final adverse decision.