G.R. No. L-13555
May 30, 1962
THE SOCIAL SECURITY COMMISSION, petitioner,
v.
THE HON. JUDGE FROILAN BAYONA, ET AL., respondents.
Facts
The Faculty Club of the University of Santo Tomas, Inc. and the San Beda College Lay Faculty Club, Inc. had a private system for retirement funds that have been in effect since September 1, 1957. They prayed for a preliminary injunction ex parte commanding the Social Security Commission (SSC) to stop compelling them to integrate their private system into the Social Security System since their private system provided more benefits. They contended that doing so would deprive their members of property without due process of law. This non-integration, however, would violate the provisions of the Social Security Law of 1954 (RA 1161), particularly Section 9 on Compulsory Coverage, which states “private plans which are existing and in force at the time of compulsory coverage shall be integrated with the plan of the SSS.” Despite this, Judge Froilan Bayona, the presiding judge of the court a quo issued the requested preliminary injunction. The SSC in this case filed a petition for certiorari on the grounds that the judge acted with grave abuse of discretion by enjoining the enforcement of a law to benefit a chosen few because the statute has the potential to be declared unconstitutional. SSC contended that a statute is presumed unconstitutional and that there is no irreparable injury to justify the issuance of the injunction.
Issues
1. Were there irreparable injuries in this case?
2. Did Judge Bayona err in granting the petition for injunction?
Ruling
1. No. An irreparable injury is defined as an injury where there is no standard by which their amount can be measured with reasonable accuracy, i.e., the damages can be estimated only by conjecture and not by any accurate standard of measurement (Crouc v. Central Labor Council and Phipps v. Rogue River Valley Canal). In this case, the damage may be computed as evidenced by the members’ lengthy discourse of the injury they may suffer if the injunction were not issues. Thus, the injury is not irreparable.
2. Yes. The allegation that a law may be unconstitutional is not enough to warrant the petition for injunction. A law is presumed constitutional until otherwise declared by judicial interpretation. The task of suspending the operation of a law even if alleged to be unconstitutional is a matter of extreme delicacy because it is an interference with the official acts not only of the duly elected representatives of the people but also of the highest magistrate of the land.Thus, until the law is indeed declared unconstitutional, any assumptions that declare otherwise bear no weight in court decisions.
The writ of preliminary injunction issued by Judge Bayona is lifted.
It's a Ping Thing 