G.R. No. L-29480. March 14, 1979.
The DIRECTOR OF FORESTRY, The SECRETARY OF AGRICULTURE AND NATURAL RESOURCES AND STA. TERESITA WOOD INDUSTRIES, INC., petitioners, vs. JUDGE FRANCISCO GERONIMO and WOODRICH INDUSTRIES, INC., respondents.

FACTS

This is a petition for certiorari and prohibition assailing the orders of the respondent Judge of the Court of First Instance of Manila in Civil Case No. 71798. The main case was a petition for certiorari and mandamus filed by respondent Woodrich Industries, Inc. (WOODRICH) against the Director of Forestry and other officials, seeking to annul administrative decisions denying its timber license application and to enforce a prior favorable decision by an Executive Secretary. The trial court issued a preliminary injunction to preserve the status quo over the contested forest area in Cagayan.
Subsequently, WOODRICH filed a Supplemental Petition, impleading Sta. Teresita Wood Industries, Inc. (STAWOOD) as an additional respondent. It alleged that STAWOOD had been granted permits for a right-of-way and camp site within the contested area and was conducting illegal logging operations there, which would render any future judgment in WOODRICH’s favor ineffectual. The respondent judge admitted the Supplemental Petition and issued a supplemental writ of preliminary mandatory injunction, setting aside STAWOOD’s permits and halting its operations.

ISSUE

Whether the respondent judge committed grave abuse of discretion or acted without jurisdiction in (1) admitting the Supplemental Petition filed by WOODRICH, and (2) issuing the supplemental writ of preliminary mandatory injunction against STAWOOD.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion or lack of jurisdiction on the part of the respondent judge. The Court held that the grounds raised by the petitioners were essentially defenses or factual assertions properly within the trial court’s domain to evaluate during a hearing on the merits. The petitioners argued that WOODRICH lacked legal personality as it held no concession, that the issues were administrative, and that WOODRICH failed to exhaust administrative remedies. However, the Court ruled that WOODRICH’s standing was intrinsically linked to the validity of the executive orders being challenged in the main petition, an issue for the trial court to resolve.
Regarding the supplemental writ, the Court found that the factual allegations in the Supplemental Petition—concerning permits granted to STAWOOD and alleged illegal logging within the contested area—provided a sufficient basis for the trial court to act to preserve the subject matter of the litigation and ensure the efficacy of a potential judgment. The petitioners’ reliance on an administrative order from the Director of Forestry dismissing WOODRICH’s complaint against STAWOOD did not preclude judicial review, as the order itself acknowledged ongoing operations, the legality of which was a judicial question. The Court emphasized that the propriety of the injunctive relief involved factual determinations to be made by the trial court after a full hearing. Ultimately, the petition was also rendered moot and academic, as the main case in the lower court had already been dismissed, a fact which the petitioners’ counsel had a duty to disclose to the Court earlier.