G.R. No. 93359; July 12, 1991
Republic of the Philippines, represented by the Air Transportation Office and its Pre-qualification, Bidding and Award Committee of the Department of Transportation and Communication, petitioners, vs. Honorable Ignacio C. Capulong, Presiding Judge, RTC, NCJR, Branch 134, Makati, and Inter Technical Pacific Phil., Inc., respondents.

FACTS

The Air Transportation Office (ATO) invited prequalified bidders for a government infrastructure project financed by a Japanese loan. Inter Technical Pacific, Inc., a prequalified bidder, submitted its sealed bidding documents. During the bid opening, the ATO’s Pre-qualification, Bidding and Award Committee (PBAC) discovered that Inter Technical’s submission lacked the required “Form of Bid.” Despite Inter Technical’s protest that the omission was inadvertent, that its bid price and bond were evident in other documents, and its offer to immediately supply the form, the PBAC rejected the bid as non-complying.
Inter Technical appealed to the ATO and the Department of Justice, which opined the bid was invalid, citing bidding rules that disqualify non-complying bids and noting the Form of Bid contains essential contractual commitments. Inter Technical then filed a complaint with the Regional Trial Court, which granted a writ of preliminary injunction, ordering the PBAC to reconvene and consider Inter Technical’s bid. The ATO and PBAC petitioned the Supreme Court, arguing the trial court lacked jurisdiction due to P.D. No. 1818, which prohibits courts from issuing injunctions in government infrastructure disputes.

ISSUE

Whether the Regional Trial Court had jurisdiction to issue a writ of preliminary injunction against the PBAC’s rejection of a bid in a government infrastructure project.

RULING

The Supreme Court granted the petition and annulled the lower court’s orders. The legal logic is anchored on the explicit prohibition under Presidential Decree No. 1818, which states that “no court in the Philippines shall have jurisdiction to issue any restraining order, preliminary injunction, or preliminary mandatory injunction in any case, dispute, or controversy involving an infrastructure project” of the government. This prohibition is absolute and allows for no exceptions, aiming to prevent judicial delays that could derail critical public projects. The Court found that the Nationwide Air Navigation Facilities Modernization Project is unquestionably an infrastructure project. Therefore, the trial court acted without jurisdiction when it issued the injunction. The Court further noted that the PBAC’s decision to reject the bid for lacking a mandatory document was reached after fair deliberation. Since the trial court lacked jurisdiction from the outset, its subsequent orders were void. The award process was allowed to proceed.