Republic of the Philippines versus Hon.

Ramon Caguioa, Metatrans Trading International - Whether or not the respondent judge violated the Republic’s right to due process
Corporation, and Hundred Young Subic International, Inc. when he peremptorily allowed the private respondents’ motions and complaints-in-
intervention and proceeded with their hearing ex parte despite the absence of any
GR 174385 February 20, 2013
prior notice to it.
FACTS:
DECISION:
- Petition for certiorari and prohibition challenging the order of Judge Caguioa granting
- Petition PARTIALLY GRANTED
the motion to intervene filed by private respondents and the order that denied the
- Writ of certiorari GRANTED setting aside the assailed orders of the respondent judge
motion for reconsideration and the motion to suspend proceedings filed by the
- Writ of prohibition DISMISSED for mootness
Republic
- Indigo Distribution Corporation and 13 other petitioners filed before the respondent RATIONALE:
judge a petition for declaratory relief with prayer for TRO and preliminary mandatory
- The Republic was denied due process; the respondent judge issued the assailed orders
injunction against the Sec. of Finance to nullify the implementation of Sec. 6 of RA
with grave abuse of discretion
9334 (AN ACT INCREASING THE EXCISE TAX RATES IMPOSED ON ALCOHOL AND
- Due process of law is a constitutionally guaranteed right reserved to every litigant.
TOBACCO PRODUCTS, AMENDING FOR THE PURPOSE SECTIONS 131, 141, 142, 143, 144,
Even the Republic as a litigant is entitled to this constitutional right, in the same
145 AND 288 OF THE NATIONAL INTERNAL REVENUE CODE OF 1997, AS AMENDED) as
manner and to the same extent that this right is guaranteed to private litigants. The
unconstitutional
essence of due process is the opportunity to be heard, logically preconditioned on
- RTC granted the petitions despite the Republic’s opposition
prior notice, before judgment is rendered
- Republic filed before the SC a petition for certiorari and prohibition (GR 168584) to
- A motion for intervention, like any other motion, has to comply with the mandatory
annual the judge’s order and the writ issued – petition asked for TRO and/or a writ of
requirements of notice and hearing, as well as proof of its service, save only for those
preliminary injunction.
that the courts can act upon without prejudice to the rights of the other parties. A
o Republic also asked the judge to suspend proceedings pending resolution of
motion which fails to comply with these requirements is a worthless piece of paper
GR 168584
that cannot and should not be acted upon.
- Private respondents filed motions for leave to intervene and to admit complaints-in-
- In the same way that an original complaint must be served on the defendant, a copy
intervention.
of the complaint-in-intervention must be served on the adverse party with the
- Without acting on the Republic’s motion to suspend the proceedings, the respondent
requisite proof of service duly filed prior to any valid court action.
judge granted the private respondents’ motions and complaints-in-intervention.
o Absent these or any reason duly explained and accepted excusing strict
o Respondent judge found the private respondents to be similarly situated as
compliance, the court is without authority to act on such complaint; any
the lower court petitioners
action taken without the required service contravenes the law and the rules,
- Republic moved to reconsider the Judge’s order arguing that it had been denied due
and violates the adverse party’s basic and constitutional right to due process.
process because it never received copies of the private respondents’ motions and
- OSG had never received a copy of the motions and complaints-in-intervention.
complaints-in-intervention
o The above motion and complaints are but a mere scrap of paper that the
o Judge denied the above motion and the motion to suspend proceedings
judge had no reason to consider
o Judge pointed to the absence of any restraining order in GR 168584
- In admitting them despite the absence of prior notice, the respondent judge denied
the Republic of its right to due process and acted with grave abuse of discretion.

ISSUE:

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