**Facts:**
Petitioners Spouses Prudente D. Soller and Preciosa M. Soller, Raffy Telosa, and Gavino Manibo, Jr. were the owners of properties near the Strong Republic Nautical Highway in Poblacion, Bansud, Oriental Mindoro. They alleged that, due to a highway elevation project executed by King’s Builder and Development Corporation, their safety and properties were placed in imminent danger. Specifically, they claimed that the elevation blocked natural floodwater flow from the Bansud River and nearby farmlands, causing flooding in their areas and impairing property access.
Petitioners sought a Permanent Injunction and damages, along with a Temporary Restraining Order (TRO)/Preliminary Injunction, against Secretary Rogelio Singson and Engineer Magtanggol Roldan of the Department of Public Works and Highways (DPWH), and King’s Builder and Development Corporation, including its president, Engr. Elegio Malaluan.
The initial trial stage involved the Respondents filing a Motion to Dismiss, claiming that Presidential Decree No. 1818 forbids injunctions against national government projects and asserted the State’s immunity from suit. The Regional Trial Court (RTC) of Pinamalayan, Oriental Mindoro, Branch 41 dismissed the petition on July 10, 2014, citing a lack of jurisdiction over the injunction request per Republic Act (R.A.) No. 8975.
Petitioners filed a Motion for Reconsideration, subsequently denied by RTC on November 18, 2014. Appealing to the Supreme Court, petitioners argued that the RTC had jurisdiction over the principal action of injunction despite the ancillary remedy issues.
**Issues:**
1. Did the RTC have jurisdiction over the case involving a principal action for injunction despite the statutory provisions of R.A. No. 8975, which restricts lower courts from issuing TROs or preliminary injunctions against national government projects?
2. Was the filing of a direct appeal to the Supreme Court via Rule 45 the appropriate remedy for petitioners?
**Court’s Decision:**
1. **RTC’s Jurisdiction Over Injunction Actions**:
The Supreme Court clarified that the prohibition under R.A. No. 8975 applies to temporary restraining orders and preliminary injunctions, not to permanent injunctions issued after an adjudication on the merits. Hence, the RTC had jurisdiction over the principal action (permanent injunction), as it was separate from the preliminary ancillary remedies. Therefore, the Supreme Court resolved that the RTC had erroneously dismissed the case on jurisdiction grounds.
2. **Appropriate Remedy and Jurisdiction**:
The Supreme Court noted that the petitioners should have filed a special civil action for certiorari under Rule 65 instead of a direct appeal under Rule 45, due to the nature of the dismissal (lack of jurisdiction being non-prejudicial). Nonetheless, recognizing the flexibility in procedural rules in instances where strict adherence would deny substantial justice, the Supreme Court opted to overcome this procedural error to ensure justice and equity were served.
**Doctrine:**
– **Jurisdiction Over Permanent Injunctions**: R.A. No. 8975 restricts lower courts from issuing TROs or preliminary injunctions related to government infrastructure projects but does not prohibit such courts from adjudicating cases for permanent injunctions.
– **Procedural Remedy Flexibility**: The Court emphasized the importance of substantive justice over procedural technicalities, allowing it to entertain petitions even if filed under incorrect procedural rules where rigid application would unjustly defeat legal fairness.
**Class Notes:**
– **Jurisdiction Determination**: Courts’ jurisdiction is dictated by the principal relief sought and the allegations within the complaint.
– **Government Projects and Injunctions**: Lower courts are barred from issuing TROs and preliminary injunctions against the execution of government projects, but permanent injunctions upon final case adjudication are allowed.
– **Doctrine of State Immunity**: While the State’s immunity can negate certain suits, it does not extend to suits filed for injunction if proper jurisdiction and procedural rules are followed.
**Historical Background:**
Republic Act (R.A.) No. 8975 is significant in demarcating the limits of judicial interventions in government projects to expedite infrastructure development. This case establishes a clear interpretation of how such statutory limitations are balanced against the judiciary’s role in adjudicating substantive rights through permanent injunctions beyond preliminary constraints.
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