Tambaoan v. Court of Appeals
REITERATIONFacts
The Antecedents: Elected barangay captains of Mapandan, Pangasinan, filed a case against Thelma P. Quinto and others who claimed legitimacy as officers of the Liga ng mga Barangay (ABC) by virtue of appointments from the National Liga ng mga Barangay President. The plaintiffs alleged that Quinto and her group walked out of an election meeting, and subsequently, Loreto Aquino was elected President and recognized by the DILG. However, the National Liga President recalled Aquino's confirmation due to procedural defects and later appointed Quinto as president. Quinto filed a petition for nullity of Aquino's election with the DILG. Procedural History: Loreto Aquino and his co-plaintiffs filed an action for "Declaration of Nullity of Appointments, Issuance of Temporary Restraining Order, Injunction and Damages" before the RTC. The RTC initially issued a TRO but later denied the application for a preliminary injunction, finding no merit and lifting the TRO. The RTC cited failure to exhaust administrative remedies, pendency of a case before the DILG, lack of legal personality of some plaintiffs, failure of elections, recall of Aquino's confirmation, validity of Quinto's appointment, and readiness of defendants to assume office. A motion for reconsideration was denied, and the RTC allowed Quinto to assume office. An alias writ of execution was issued. Quinto reported for work but was prevented from entering the session hall by petitioners. She was constrained to hold office in the corridors and demanded her salary, which was not paid. The case was raffled to another judge. The DILG requested compliance with the RTC order. Quinto filed another motion for alias writ of execution and contempt, which was opposed. Quinto filed a third-party complaint against municipal officials. The RTC granted the alias writ of execution, ordering the municipal officials to pay Quinto's salary. Quinto then filed a petition for mandamus with the Court of Appeals (CA) due to continued inaction. The RTC later recalled the alias writ of execution, reconsidering its previous order. Quinto moved for reconsideration, which was denied. Quinto amended her petition to include certiorari of the RTC orders. The CA set aside the RTC orders, ordered the enforceability of the January 6, 1995 order, and remanded the case for reception of evidence on damages. The Petition: Petitioners sought review of the CA decision, raising issues on the validity of Quinto's appointment, her right to serve as an ex-officio member of the Sangguniang Bayan, the finality and enforceability of the January 6, 1995 RTC order, and whether the RTC orders of November 6, 1996, and December 18, 1996, were issued with grave abuse of discretion.
Issue(s)
Whether the appointment of respondent Thelma P. Quinto as President of the Liga ng mga Barangay is valid, and whether she can serve as ex-officio member of the Sangguniang Bayan of Mapandan, Pangasinan, on the basis of her appointment. Whether the Order of January 6, 1995, issued by Judge Deodoro J. Sison, Branch 40 of the RTC, is a valid final or interlocutory order. Whether the Order of January 6, 1995, is enforceable, as ordered by the Court of Appeals. Whether the RTC Orders of November 6, 1996, and December 18, 1996, were issued without jurisdiction or in excess of jurisdiction or with grave abuse of discretion.
Ruling
The petition is granted. The decision and resolution of the Court of Appeals are reversed and set aside. The case is remanded to the court of origin for further proceedings on the merits, with a directive to proceed and dispose of Civil Case No. 94-00321-D with dispatch.
Ratio Decidendi
On the validity of Quinto's appointment and her right to serve as ex-officio member: The Supreme Court found it inopportune to rule on these issues at this stage without prejudging the merits of the case. The primary issue in the original action was the declaration of nullity of appointments and damages, and the RTC had not yet conducted a hearing on the merits. The inquiry into the issuance or denial of a preliminary injunction is based solely on initial evidence and is provisional. On whether the Order of January 6, 1995, is a valid final or interlocutory order: The Supreme Court held that the Order of January 6, 1995, which denied the motion for reconsideration of the order denying the preliminary injunction, was merely interlocutory. It did not terminate or finally dispose of the case, as substantial proceedings, including the determination of the principal action for declaration of nullity of appointment and damages, were yet to be had. The court's task of adjudicating the parties' contentions and determining their rights and liabilities was not concluded. On whether the Order of January 6, 1995, is enforceable: As the Order of January 6, 1995, was merely interlocutory, it could not be appealed independently of the main case. It could only be assailed as part of an appeal from the final judgment in the main case. The extraordinary remedy of certiorari could have been availed of, but the petitioners, who were discharging their duties, obviously did not need to resort to it. Therefore, the CA erred in ordering the enforceability of this interlocutory order. On whether the RTC Orders of November 6, 1996, and December 18, 1996, were issued with grave abuse of discretion: The Supreme Court found merit in the petition, implying that the CA erred in reversing the RTC's recall of the alias writ of execution. The RTC, in recalling the writ, correctly noted that the municipal officials ordered to pay salaries were not parties to the case, violating their due process rights. The RTC's subsequent order was deemed a valid reconsideration of a previous erroneous order, as it correctly identified that the case had not yet been decided on its merits.
Main Doctrine
An order that leaves substantial proceedings yet to be had in connection with the controversy is interlocutory and not subject to execution or appeal independently of the main case. The inquiry in proceedings for the issuance or denial of a writ of preliminary injunction is premised solely on initial evidence and is provisional until after the trial on the merits.