Technology Developers v. Court of Appeals, et al.

Technology Developers, the Petitioner, was a private corporation engaged in the manufacture and export of charcoal briquettes. The mayor of Bulacan, a nearby town, sent a letter to Technology Developers, expressing concern over the pollution emitted by the Petitioner in the form of fumes that “not only pollute the air in the locality but also affect the health of the residents in the area.” The letter ordered the corporation to shut down their plant until further notice. It also requested the plant manager to present a building permit, a mayor’s permit, and an anti-pollution permit to the mayor. Technology Developers was unable to secure the mayor’s permit. A few months later, Cruz ordered the municipality’s station commander to padlock the premises of Technology Developer’s plant, effectively stopping its operations.

Technology Developers filed a petition alleging that the closing of their plant was unlawful. They obtained a preliminary injunction from the trial court to prevent the closure of their operations. The trial court later dissolved the injunction after Technology Developers was unsuccessful both at trial and on appeal. Technology Developers sought to contest the order to dissolve their preliminary injunction before the Supreme Court.

The Court held that the trial court was correct to dissolve the injunction. It emphasized that there needed to be sound reasons to disturb the trial court’s decision to grant or withhold an injunction. In the Court’s opinion, the Mayor was authorized to shut down Technology Developer’s plant for the lack of a permit, and the decision had been taken in response to both complaints and an investigation into the pollution coming from the plant. Further, despite having their attention called to the pollution, Technology Developers had made no attempt to validate its permits or mitigate the fumes coming from its plant. As such, the Court considered that dissolving the injunction was the correct course of action.

The Court also noted that while there was a need to promote investment and contribute to the growth of the economy, it was more important to protect the health and lives of citizens from the negative effects of environmental pollution. 

“While it is true that the matter of determining whether there is a pollution of the environment that requires control if not prohibition of the operation of a business is essentially addressed to the then National Pollution Control Commission of the Ministry of Human Settlements, now the Environmental Management Bureau of the Department of Environment and Natural Resources, it must be recognized that the mayor of a town has as much responsibility to protect its inhabitants from pollution, and by virtue of his police power, he may deny the application for a permit to operate a business or otherwise close the same unless appropriate measures are taken to control and/or avoid injury to the health of the residents of the community from the emissions in the operation of the business.” Page 4.

“Petitioner takes note of the plea of petitioner focusing on its huge investment in this dollar-earning industry. It must be stressed however, that concomitant with the need to promote investment and contribute to the growth of the economy is the equally essential imperative of protecting the health, nay the very lives of the people, from the deleterious effect of the pollution of the environment.” Page 5.