G.R. No. L-19828. February 28, 1963.
GUSTAVO A. SUAREZ, petitioner, vs. HON. ANDRES REYES, Judge of the Court of First Instance of Rizal, and TIMBERMAN CORPORATION, respondents.

FACTS

Petitioner Gustavo A. Suarez and respondent Timberman Corporation submitted competing bids for a timber concession. The Director of Forestry awarded the concession to Timberman, a decision affirmed by the Secretary of Agriculture and Natural Resources. Suarez appealed to the President. Pending this appeal, the Executive Secretary, acting for the President, directed that execution of the Secretary’s decision be held in abeyance. Despite this, the Director of Forestry issued a temporary timber license to Timberman. Subsequently, the President reversed the Secretary’s decision and awarded the concession to Suarez. The Director of Forestry then ordered the stoppage of Timberman’s operations under its temporary license.
Timberman filed a second motion for reconsideration with the President. Before its resolution, Timberman filed a petition for certiorari and/or prohibition with the Court of First Instance of Rizal against the Executive Secretary, the Secretary of Agriculture, the Director of Forestry, and Suarez. Timberman alleged the President’s decision was based on hearsay evidence and constituted grave abuse of discretion. The respondent Judge issued a writ of preliminary injunction, ordering the forestry officials to refrain from cancelling Timberman’s license and from issuing any license to another for the area, effectively maintaining the status quo.

ISSUE

Whether the respondent Judge acted without or in excess of jurisdiction or with grave abuse of discretion in taking cognizance of Civil Case No. 6968 and in issuing the writ of preliminary injunction therein.

RULING

Yes, the respondent Judge committed a grave abuse of discretion in issuing the preliminary injunction. The Supreme Court clarified that while the lower court was not entirely devoid of jurisdiction to take cognizance of the case, its issuance of the injunction was premature and improper. The authority to grant, cancel, or extend timber licenses resides exclusively within the executive department, specifically the Director of Forestry, subject to review by the Secretary of Agriculture and Natural Resources and ultimately the President. Judicial review of such administrative actions is permissible only upon a clear showing of grave abuse of discretion, lack of jurisdiction, or denial of due process after the administrative proceedings have run their course.
At the time the injunction was issued, the administrative process was not yet final, as Timberman’s second motion for reconsideration was still pending with the President. The injunction effectively extended the life of Timberman’s temporary license, which had expired, thereby usurping the executive’s prerogative. The Court held that the propriety of the evidence considered by the President was a matter to be first fully ventilated in the administrative sphere. By interposing judicial power to alter the administrative course prematurely, the respondent Judge committed a grave abuse of discretion. Consequently, the Supreme Court annulled and set aside the writ of preliminary injunction issued by the lower court.