G.R. No. 99042 September 26, 1994
BLOOMFIELD ACADEMY AND RODOLFO J. LAGERA, petitioners, vs. THE HONORABLE COURT OF APPEALS, BLOOMFIELD ACADEMY PARENTS ADVISORY ASSOCIATION, INC. (BAPAA), represented by its Vice-President, Menardo Bordeos; and The Hon. SALVADOR P. DE GUZMAN, JR., Presiding Judge of the Regional Trial Court, National Capital Judicial Region, Branch 142, Makati, Metro Manila, respondents.

FACTS

The Bloomfield Academy Parents Advisory Association, Inc. (BAPAA) filed a complaint for injunction against Bloomfield Academy and Rodolfo J. Lagera before the Regional Trial Court (RTC). The complaint challenged the school’s implementation of a tuition fee increase for the school year 1990-1991, averaging 21.22%. BAPAA alleged the increase was made without prior consultation with parents as required by law, was grossly inappropriate, and violated a prior agreement where only 50% of a proposed increase would be collected. The RTC issued a writ of preliminary injunction, ordering the petitioners to limit collection to the first P675.00 of the increase and not to withhold students’ report cards. Petitioners filed a special civil action for certiorari with the Court of Appeals, assailing the RTC’s issuance of the writ. The Court of Appeals dismissed the petition, ruling that the grant or denial of an injunction rests on the sound discretion of the trial court and that the errors assigned were errors of judgment, not jurisdiction, and thus not correctible by certiorari. Petitioners elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Regional Trial Court acted within its jurisdiction in issuing the writ of preliminary injunction and, if so, whether it committed grave abuse of discretion in granting the application for the writ.

RULING

The Supreme Court GRANTED the petition. It held that the RTC was bereft of jurisdiction to take cognizance of BAPAA’s complaint for injunction. The Court ruled that the Department of Education, Culture and Sports (DECS) Secretary, in approving the tuition fee increase, acted in a quasi-judicial capacity. The exclusive appellate jurisdiction to question that administrative action lies with the Court of Appeals, not with the RTC. Furthermore, the complaint could not be treated as a special civil action for certiorari or prohibition as it contained no allegation of lack or grave abuse of jurisdiction by the DECS. The Court also noted that the parties remained silent on the arbitration provision under Republic Act No. 6728 for resolving disagreements on tuition fee increases. Consequently, the questioned order of the RTC and the decision of the Court of Appeals were SET ASIDE.