G.R. No. L-35007. December 29, 1980.
THE CHIEF OF STAFF, AFP; COMMANDING GENERAL, FIRST INFANTRY DIVISION, PA; and COMMANDING OFFICER, TASK FORCE “PRESERVE”, petitioners, vs. HON. TEOFILO GUADIZ, JR., as Judge of the Court of First Instance (Fifth Branch) of Nueva Ecija; and DIOSAMER DEVELOPMENT CORPORATION, represented by its General Manager, Minor B. Bote, respondents.

FACTS

The private respondent, Diosamer Development Corporation, filed a complaint (Civil Case No. 644) in the Court of First Instance of Nueva Ecija against the military petitioners. The corporation sought a road right-of-way through the Fort Magsaysay Military Reservation, specifically requesting an injunction to prevent the military from stopping its logging trucks and personnel from using the Bignay and Sumandig-Alulag roads, which traversed the reservation. The respondent Judge, Teofilo Guadiz, Jr., issued an ex-parte temporary restraining order on January 27, 1972, allowing the corporation to cut, remove, and transport logs from its licensed area pending a hearing.
Subsequently, upon the corporation’s urgent motion, the respondent Judge issued a clarificatory order on February 11, 1972. This order extended the restraining order’s effectivity indefinitely and explicitly permitted logging operations within the corporation’s licensed area “notwithstanding the respective conflicting claims of the defendants and the plaintiff that said area is inside or outside the Fort Magsaysay Military reservation.” The petitioners’ motion for reconsideration was denied by the court in its order dated April 6, 1972, which also directed the issuance of a writ of preliminary injunction.

ISSUE

Whether the respondent Judge acted with grave abuse of discretion amounting to lack of jurisdiction in issuing the ex-parte restraining order and the subsequent clarificatory order.

RULING

Yes, the Supreme Court granted the petition for certiorari and prohibition, setting aside the challenged orders. The Court ruled that the respondent Judge committed grave abuse of discretion. The legal logic is clear: the clarificatory order of February 11, 1972, exceeded the relief sought in the original complaint. The complaint merely prayed for a right of way to pass through the military reservation. However, the clarificatory order effectively authorized the corporation to conduct logging operations within the contested area, thereby prejudging the core factual dispute—whether the corporation’s licensed area was inside or outside the military reservation. This amounted to an adjudication on the merits without a proper trial, which is a fundamental violation of procedural due process. The Court emphasized that sound judicial discretion cannot be used to frustrate the law or defeat its objectives. By granting relief beyond the pleadings and deciding a critical factual issue ex-parte, the respondent Judge’s orders were issued without jurisdiction. Consequently, the order of April 6, 1972, which denied the motion for reconsideration and perpetuated this error, was likewise void.