Chemplex Philippines, Inc. v. Pamatian
REITERATIONFacts
1. The Antecedents: The underlying dispute involves a controversy between Chemplex (Philippines) Inc. and Tommy P.S. Lim, and respondents Benigno D. Lim, Carmen L. Lim, Aquiles J. Lopez, and Sixto T. Antonio. The specifics of the dispute are not detailed in the provided text, but it concerns a matter that led to a petition for a writ of preliminary injunction. 2. Procedural History: The case originated in the Court of First Instance of Rizal, presided over by Judge Ramon C. Pamatian. Judge Pamatian issued an order on August 29, 1973, concerning the issuance of a writ of preliminary injunction after a hearing and reception of evidence. This order was subsequently challenged by the petitioners, Chemplex (Philippines) Inc. and Tommy P.S. Lim, through a petition for certiorari filed with the Supreme Court. 3. The Petition: The petitioners filed a petition for certiorari with the Supreme Court, challenging the August 29, 1973 order issued by Judge Pamatian regarding the preliminary injunction. They sought to have this order reviewed. The Supreme Court, after reviewing the extensive pleadings and annexes, resolved to dismiss the petition for lack of merit, finding no grave abuse of discretion on the part of the respondent judge. A restraining order previously issued on September 11, 1973, was also lifted.
Issue(s)
Whether the respondent Judge committed a grave abuse of discretion amounting to lack or excess of jurisdiction in issuing the writ of preliminary injunction. Whether the Supreme Court, in a petition for certiorari, should act as a trier of facts and substitute its own factual findings for those of the trial court.
Ruling
The Supreme Court RESOLVED to dismiss the petition for lack of merit, finding no showing of grave abuse of discretion, and to lift the restraining order dated September 11, 1973. The Court further RESOLVED unanimously to direct the respondent Court to act on the case with reasonable dispatch and to suggest the advisability of a receivership.
Ratio Decidendi
On Whether the respondent Judge committed a grave abuse of discretion amounting to lack or excess of jurisdiction in issuing the writ of preliminary injunction: The Court found no merit in the petition for certiorari, holding that there was no showing of grave abuse of discretion on the part of the respondent Judge. The Judge issued the order after due hearing and reception of evidence concerning the incident for the issuance of a writ of preliminary injunction. The Court noted that the Judge issued the writ based on the facts as found by him, subject to further consideration of the case on the merits after trial, considering the interlocutory nature of the injunction. The Court found his factual findings to be circumspect, reasoned out, and arrived at after serious judicial inquiry, and not arbitrary or unsupported by the evidence. On Whether the Supreme Court, in a petition for certiorari, should act as a trier of facts and substitute its own factual findings for those of the trial court: The Court unequivocally stated that it is not a trier of facts. It is beyond its function to make its own findings of certain vital facts different from those of the trial court, especially on the basis of conflicting claims of the parties and without the evidence being properly before it. For the Supreme Court to make such factual conclusions would be unjustified because if material facts are controverted and are issues being litigated before the lower court, the petition for certiorari would not be in aid of the appellate jurisdiction of the Supreme Court. Furthermore, it would preempt the primary function of the lower court, which is to try the case on the merits, receive all the evidence, and then come to a definite decision, including the maintenance or discharge of the preliminary injunction.
Main Doctrine
The Supreme Court reiterated that a petition for certiorari under Rule 65 of the Rules of Court is an extraordinary remedy that lies only when a tribunal, board, or officer exercising judicial, quasi-judicial, or ministerial functions has acted without or in excess of its jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction. It is not a remedy for the correction of errors of judgment or for the re-examination of the evidence presented before the lower court. The Court emphasized that it is not a trier of facts and will not substitute its own factual findings for those of the trial court, especially when the evidence is conflicting and not properly before it.