Javier v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from the expropriation of the Gonzales Estate, a large tract of land in Caloocan City, by the Philippine government in 1947 for distribution to its occupants and tenants. The property was eventually acquired by the Philippine Housing and Homesite Corporation (PHHC). A subsequent presidential order in 1960 limited the area to be sold per tenant to one thousand square meters, with the remainder to be sold to other low-income families. This decision was contested by seventy-five occupants-tenants, including Gregorio Bajamonde, who sought to compel the PHHC to sell the entire property exclusively to them. This led to protracted litigation involving various compromise agreements, deeds of sale, and title issuances concerning Lots 54 and 75, occupied by Gregorio Bajamonde and his wife Saturnina. 2. Procedural History: The case has a complex procedural history spanning decades and multiple lower courts and administrative bodies. It began with the expropriation of the Gonzales Estate and subsequent disputes over its resale to tenants. Numerous compromise agreements were entered into between tenants, the PHHC (later NHA), and the Araneta Institute of Agriculture (later Gregorio Araneta University Foundation - GAUF), leading to conflicting claims and titles over Lots 54 and 75. These disputes resulted in multiple civil cases, including actions for annulment of agreements, execution of judgments, and petitions for mandamus and prohibition. The heirs of Gregorio Bajamonde sought to enforce their rights, leading to orders for eviction and demolition of structures built by GAUF employees. These orders were challenged through various petitions for certiorari and prohibition before the Court of Appeals (CA) and this Court, with varying outcomes. 3. The Petition: This petition for review on certiorari under Rule 45 of the Rules of Court seeks to annul the Resolution of the Court of Appeals (CA) dated September 27, 1990, which dismissed the petitioners' petition for certiorari and prohibition for being insufficient in substance, and its subsequent Resolution dated March 8, 1991, denying their motion for reconsideration. The petitioners argued that the CA erred in dismissing their petition, asserting that a writ of certiorari and prohibition could issue to nullify an interlocutory order denying a motion to dismiss on grounds of res judicata and forum shopping, and an order granting a preliminary injunction that interfered with the orders of a co-equal court, thereby violating the doctrine of judicial stability. They contended that their petition sufficiently demonstrated grave abuse of discretion by the trial court and that appeal was not a speedy and adequate remedy.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari and prohibition for being insufficient in substance. Whether the Regional Trial Court committed grave abuse of discretion amounting to excess or lack of jurisdiction in issuing a writ of preliminary injunction that interfered with the orders of a co-equal court, thus violating the doctrine of judicial stability. Whether the petition for certiorari and prohibition was the proper remedy despite the availability of an appeal.
Ruling
The Supreme Court granted the petition, setting aside and reversing the Resolutions of the Court of Appeals dated September 27, 1990, and March 8, 1991. The CA was directed to redocket CA-G.R. SP No. 22761 and continue with the proceedings therein.
Ratio Decidendi
On the sufficiency of the petition for certiorari and prohibition: The Court held that the petition filed before the Court of Appeals was sufficient in substance. A petition for certiorari or prohibition is sufficient in substance if it demonstrates plainly and distinctly all the facts essential to establish a right to the writ, or at least a prima facie basis for its issuance. The petition must allege facts showing that any existing remedy is not speedy or adequate and that the respondent tribunal acted without or in excess of jurisdiction or with grave abuse of discretion. The Court found that the petition sufficiently alleged that the RTC judge issued the order with grave abuse of discretion and that appeal would not be a speedy and adequate remedy, especially considering the potential violation of judicial stability. On the alleged grave abuse of discretion and violation of judicial stability: The Court agreed with the petitioners that the CA should not have dismissed the petition outright. The petitioners averred that the RTC judge violated the policy of judicial stability by issuing a writ of preliminary injunction that enjoined the eviction of private respondents from property, thereby interfering with the orders of Branch 120 of the RTC in Civil Case No. C-760. The principle of judicial stability dictates that no court has the power to interfere by injunction with the judgments, decrees, or orders of a court of concurrent or coordinate jurisdiction. The RTC judge's issuance of the injunction, which effectively stayed the execution of orders from a co-equal branch, constituted a grave abuse of discretion. On the propriety of certiorari as a remedy: The Court reiterated that a writ of certiorari may be granted even if an appeal is available, particularly when there is a prima facie showing that the trial court issued the order with grave abuse of discretion, appeal would not be speedy and adequate, the order is a patent nullity, or the decision will arrest future litigation. In this case, the alleged violation of judicial stability and the denial of a motion to dismiss on grounds of res judicata and forum shopping warranted the issuance of the writ. The CA should have at least ordered the private respondents to comment on the petition instead of dismissing it outright, especially since the issue of whether the plaintiffs were builders in bad faith could have been raised in the still-pending Civil Case No. C-760.
Main Doctrine
A petition for certiorari and prohibition may be granted to nullify an interlocutory order denying a motion to dismiss on grounds of res judicata and forum shopping, and an order granting a writ of preliminary injunction that impedes the enforcement of a co-equal court's order, thereby violating the doctrine of judicial stability. The Court of Appeals should not have dismissed the petition outright but should have ordered the respondents to comment.