Ley Construction & Development Corporation v. Hyatt Industrial Manufacturing Corporation
REITERATIONFacts
1. The Antecedents: Ley Construction & Development Corporation (petitioner) filed a complaint for specific performance and damages against Hyatt Industrial Manufacturing Corporation, later impleading Princeton Development Corporation and Yu He Ching (respondents). The core of the dispute involved petitioner's attempt to conduct depositions of key individuals, which was subsequently cancelled by the trial court. 2. Procedural History: The case originated in the Regional Trial Court (RTC) of Makati. After initial skirmishes and amendments to the complaint, the RTC issued orders on September 17, 1996, and October 14, 1996, cancelling scheduled depositions and setting the case for pre-trial. Petitioner's subsequent motion for reconsideration was denied. Following the denial, petitioner was declared non-suited and its complaint dismissed. Petitioner then filed a Conditional Notice of Appeal, which is currently pending. Prior to this appeal, petitioner also filed a Petition for Certiorari with the Court of Appeals (CA) assailing the RTC's orders regarding depositions. 3. The Petition: The petitioner filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's July 24, 1997, and March 4, 1998, Resolutions. The CA had denied due course to the Petition for Certiorari, deeming it moot and academic because the issues raised regarding the cancelled depositions were also part of the pending appeal. The Supreme Court is asked to determine if the CA erred in dismissing the Petition for Certiorari on grounds of mootness and forum shopping, considering that the appeal also questioned the same interlocutory orders.
Issue(s)
Whether the Court of Appeals committed reversible error in dismissing the petition for certiorari as moot and academic. Whether the Court of Appeals committed reversible error in not nullifying the RTC Orders dated September 17 and October 14, 1996, which allegedly deprived petitioner of its right to discovery.
Ruling
The Supreme Court denied the petition and affirmed the Resolutions of the Court of Appeals, holding that the petition for certiorari was indeed moot and academic.
Ratio Decidendi
On the issue of mootness of the Petition for Certiorari: The Court held that the petition for certiorari was rendered moot and academic by the subsequent filing of an appeal. The petition sought to set aside only the interlocutory orders regarding discovery, not the final resolution dismissing the complaint. Granting the certiorari petition would have no practical effect if the complaint itself had already been dismissed. The subsequent appeal, which assailed both the dismissal resolution and the interlocutory orders, constituted a plain, speedy, and adequate remedy, rendering the certiorari petition unnecessary. The Court emphasized that certiorari is available only when there is no appeal or other adequate remedy, and these remedies are mutually exclusive. The existence of the appeal adequately addressed petitioner's rights, preventing a failure of justice. Furthermore, the Court noted that petitioner's argument that the certiorari petition had a practical effect implied that it sought the same relief as the appeal, potentially constituting forum shopping. On the alleged distinction between the two actions: The Court rejected petitioner's argument that the certiorari petition presented a different issue (due process right to discovery) from the appeal (propriety of the dismissal). The Court found that the appeal's assignments of error explicitly included the cancellation of depositions and the denial of the motion to suspend proceedings, thereby encompassing the issues raised in the certiorari petition. Therefore, the appeal was the appropriate remedy, and the CA did not err in deeming the certiorari petition moot and academic.
Main Doctrine
A petition for certiorari is rendered moot and academic by a subsequent appeal that assails not only the final resolution dismissing the complaint but also the interlocutory orders earlier challenged in the certiorari petition, as the appeal constitutes a plain, speedy, and adequate remedy.