G.R. No. L-13555; May 30, 1962
THE SOCIAL SECURITY COMMISSION, petitioner, vs. THE HON. JUDGE FROILAN BAYONTA, ET AL., respondents.

FACTS

The Faculty Club of the University of Santo Tomas, Inc. and the San Beda College Lay Faculty Club, Inc. filed a petition for declaratory relief with a plea for a preliminary injunction before the Court of First Instance of Manila. They alleged that they had existing private gratuity and retirement fund agreements with their respective educational institutions, established and operational prior to September 1, 1957. The Social Security Commission sought to compel the integration of these private plans into the compulsory Social Security System. The faculty clubs argued that such forced integration would deprive their members of property without due process and impair contractual obligations, as their private plans allegedly offered superior benefits.
Respondent Judge Froilan Bayona issued an ex parte writ of preliminary injunction, enjoining the Commission from compelling the integration pending the declaratory relief case. The Commission moved to dissolve the injunction, arguing, among other grounds, that a statute is presumed constitutional, that no irreparable injury was shown, and that injunctions do not lie against the enforcement of penal statutes or the collection of contributions under a public welfare law. The motion was denied, prompting the Commission to file this petition for certiorari, charging the judge with grave abuse of discretion.

ISSUE

Whether the respondent judge committed grave abuse of discretion in issuing the ex parte writ of preliminary injunction to enjoin the enforcement of the Social Security Act’s integration mandate.

RULING

Yes, the Supreme Court granted the petition and lifted the preliminary injunction. The legal logic centers on the requisites for injunctive relief and the presumption of constitutionality. A preliminary injunction is an extraordinary remedy requiring a clear showing of a right to be protected and that the complainant would suffer a grave and irreparable injury if the injunction is not granted. The Court found that the respondent faculty clubs failed to demonstrate such irreparable injury.
The injury claimed—potential loss of access to fund loans, the taking of contributions, and the threat of criminal prosecution—was not irreparable in law. The term “irreparable injury” refers not to the amount of damage but to the difficulty of measuring it or obtaining adequate compensation. Here, the Court noted that the Commission had assured the restoration of contributions should the challenged provision later be declared unconstitutional. Furthermore, the integration under the Social Security Act did not mandate the total destruction of the private plans; the law provided alternatives allowing the private systems to continue as a complement to the government system. Conversely, if the injunction remained and the law was ultimately upheld, the faculty clubs would be severely prejudiced by having to pay all back contributions with interest. The Court emphasized the presumption of constitutionality of statutes and the extreme delicacy of judicially suspending a social legislation. Thus, the balance of equity favored the lifting of the injunction to allow the law to operate pending a final ruling on its constitutionality.