Perez v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Emiliano M. Perez leased a space and subleased a portion to R.A. Reyes & Company, represented by respondents Luis P. Reyes and Amanda Reyes. Perez filed an ejectment case against the respondents. Respondents claimed they leased the premises directly from the owner, Mariano Guison. Procedural History: The Municipal Court of Manila ruled in favor of Perez, ordering respondents to vacate and pay rents. Respondents appealed to the Court of First Instance (CFI) of Manila. The CFI ordered execution pending appeal, despite respondents' direct rental payments to the owner, deeming it insufficient compliance. Respondents filed a petition for certiorari with the Court of Appeals (CA), alleging grave abuse of discretion by the CFI judge. The Petition: Petitioner Emiliano M. Perez filed the instant petition for certiorari and prohibition with the Supreme Court, seeking to annul a resolution of the Court of Appeals dated January 22, 1963. This resolution granted a writ of preliminary mandatory injunction to restore possession of the premises to respondents Luis P. Reyes and Amanda Reyes. Petitioner argued that the CA acted with grave abuse of discretion in issuing this preliminary injunction.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in issuing a writ of preliminary mandatory injunction. Whether the petition is moot and academic due to subsequent events.
Ruling
The Supreme Court dismissed the petition and dissolved the writ of preliminary injunction it had previously issued. It held that the issue of the preliminary mandatory injunction had been implicitly resolved by the dismissal of a related petition for review (G.R. No. L-20937) concerning the Court of Appeals' final decision that made the preliminary injunction permanent. The Court found no reason to review the propriety of the preliminary injunction after it had been superseded by a permanent one, which the Court had already declined to review.
Ratio Decidendi
On Whether the Court of Appeals committed grave abuse of discretion in issuing a writ of preliminary mandatory injunction: The Court found that the issue presented in the instant petition, which questioned the preliminary mandatory injunction, had been implicitly resolved by the dismissal of G.R. No. L-20937. In G.R. No. L-20937, the Supreme Court had dismissed a petition for review of the Court of Appeals' decision that annulled the order of execution pending appeal and made the writ of preliminary mandatory injunction permanent. Since the Supreme Court found no cause to review the appellate court's decision granting both the writ of certiorari and the final injunction sought therein, the issue in the present petition, concerning the preliminary injunction, was rendered moot. On Whether the petition is moot and academic due to subsequent events: The Court explained that its dismissal of the petition in G.R. No. L-20937 was based on the finding that there was no showing of a special and important reason for review. This dismissal did not affirm the correctness of the Court of Appeals' findings on the merits of the ejectment case, which was still pending in the Court of First Instance. However, the dismissal did resolve that the Supreme Court found no substantial reason to interfere with the Court of Appeals' discretion to place the parties in status quo as of the filing of the ejectment complaint until the case was finally decided by the lower court. Therefore, the preliminary mandatory injunction sought to be reviewed had become functus officio, having been superseded by the Court of Appeals' decision making the injunction permanent, and the subsequent petition for review of that permanent injunction had been dismissed.
Main Doctrine
The Supreme Court dismissed a petition for certiorari and prohibition seeking to annul a writ of preliminary mandatory injunction issued by the Court of Appeals. The Court found that its prior dismissal of a petition for review of the Court of Appeals' final decision, which made the preliminary injunction permanent, had already resolved the issue. Therefore, reviewing the propriety of the preliminary injunction was rendered moot and academic, as it had been superseded by the permanent injunction.