G.R. No. L-56565 June 16, 1988
RICARDO L. COOTAUCO, petitioner, vs. THE HON. COURT OF APPEALS, HON. DOMINGO M. ANGELES, Presiding Judge of Branch 1, CFI, Camarines Norte, and FELIX L. LUZARRAGA, respondents.

FACTS

The case involves a dispute over cockpit operations in Labo, Camarines Norte, a municipality with a population below 100,000. Petitioner Ricardo Cootauco was the duly licensed operator of Gallera Lapu-Lapu. Private respondent Felix Luzarraga previously operated Gallera Plaridel, whose license was revoked in 1977 for violating the location restrictions under P.D. 449 (Cockfighting Law of 1974). In 1979, an application for a renewal permit for Gallera Plaridel was denied by the PC authorities because the cockpit had ceased operations and, under Section 5(b) of P.D. 449, only one cockpit is permitted in a municipality of Labo’s size, with Cootauco already holding the valid license.
In 1980, Luzarraga filed a civil case against Cootauco and the Municipal Mayor, seeking annulment of Cootauco’s permit and a municipal resolution, and praying for a writ of preliminary injunction to stop Cootauco’s construction of a new cockpit in Barangay Bocal and its operation. The trial court issued a temporary restraining order and later a writ of preliminary injunction. Cootauco challenged these orders via certiorari in the Court of Appeals, which denied his petition, ruling any error was correctable by appeal, not a grave abuse of discretion. Cootauco then appealed to the Supreme Court.

ISSUE

Whether the trial court acted with grave abuse of discretion in issuing the injunctive writ and whether it had jurisdiction over the subject matter of the civil case.

RULING

The Supreme Court ruled in favor of petitioner Cootauco. The legal logic is anchored on the doctrine of exhaustion of administrative remedies and the specific statutory framework governing cockpit licenses. Under P.D. No. 449, the power to approve or disapprove cockpit licenses issued by municipal mayors was vested in the Chief of the Philippine Constabulary. The denial of Luzarraga’s application for renewal by the PC Provincial Commander was an administrative action appealable to the PC Chief. Luzarraga’s failure to exhaust this administrative remedy rendered his judicial action premature. Consequently, the Court of First Instance had no jurisdiction to intervene, grant relief, or issue the injunctive writs. All proceedings in the lower court, including the injunction, were therefore null and void.
Furthermore, the Court found the injunction improper as it would deprive Cootauco, a duly licensed operator, of the use of his license without lawful cause, while Luzarraga, lacking a valid license, would suffer no prejudice from its dissolution. The Court also noted the subsequent creation of the Philippine Gamefowl Commission under P.D. 1802-A, which reinforced the administrative nature of such licensing disputes. The Supreme Court set aside the Court of Appeals’ decision and the trial court’s orders, and dismissed the civil case for lack of jurisdiction.