Allgemeine-Bau-Chemie Phils. v. Metropolitan Bank
REITERATIONFacts
The Antecedents: Asian Appraisal Holdings, Inc. (AAHI) obtained a loan from Solidbank Corporation, secured by a real estate mortgage over certain lots and a condominium building. Petitioner Allgemeine-Bau-Chemie Phils., Inc. entered into a contract to sell with AAHI for several condominium units and parking slots. Petitioner was informed of the real estate mortgage and instructed to remit payments to Solidbank. Petitioner fully settled its obligation to AAHI. AAHI defaulted on its loan, leading to the extra-judicial foreclosure of the mortgage by Metropolitan Bank and Trust Company (Metrobank), to which Solidbank's banking operations were integrated. Metrobank was the highest bidder at the public auction. Metrobank filed an Ex-Parte petition for the Issuance of a Writ of Possession, which was granted by Branch 276 of the RTC of Muntinlupa. Petitioner filed a motion for intervention in AAHI's separate complaint against Solidbank, seeking annulment of the foreclosure sale and an injunction. A notice to vacate was issued. Petitioner filed a separate petition with the Court of Appeals (CA) seeking a temporary restraining order and preliminary injunction to enjoin the implementation of the writ of possession issued by Branch 276. Procedural History: The Court of Appeals (CA) initially granted a temporary restraining order but later denied petitioner's prayer for a writ of preliminary injunction, finding that petitioner failed to establish a clear and unmistakable right to the subject properties. The CA denied petitioner's motion for reconsideration. The Petition: Petitioner filed a petition for review with the Supreme Court, alleging that the CA committed grave and palpable error in denying its prayer for a writ of preliminary injunction.
Issue(s)
Whether the Court of Appeals had jurisdiction to entertain petitioner's original action for injunction. Whether the Court of Appeals committed grave and palpable error in denying petitioner's prayer for a writ of preliminary injunction.
Ruling
The petition is DENIED. The Court of Appeals committed no reversible error in denying petitioner's prayer for a writ of preliminary injunction.
Ratio Decidendi
On the issue of the Court of Appeals' jurisdiction to entertain the petition for injunction: The Court held that petitioner's original action before the Court of Appeals was an action for preliminary injunction to preserve the status quo pending the resolution of Civil Case No. 00-196 before Branch 256 of the RTC. The Court emphasized that an original action for injunction is outside the jurisdiction of the Court of Appeals, as its original jurisdiction is limited to actions for annulment of judgments of the RTCs and specific writs like mandamus, prohibition, certiorari, habeas corpus, and quo warranto. Furthermore, Section 2 of Rule 58 of the Rules of Court clearly states that a preliminary injunction may be granted by the court where the action or proceeding is pending. Petitioner's complaint-in-intervention was pending before Branch 256 of the Muntinlupa RTC, not with the appellate court. The petition before the appellate court did not allege that the RTC acted without or in excess of its jurisdiction or with grave abuse of discretion, which would have warranted treating it as a petition for certiorari or prohibition. Therefore, for want of jurisdiction, the petition before the appellate court should have been dismissed outright. On the issue of the Court of Appeals' denial of the prayer for a writ of preliminary injunction: While the primary issue was jurisdiction, the Court also noted that an order granting or denying a preliminary injunction is not appealable. The Court of Appeals' denial of the preliminary injunction was based on petitioner's failure to establish a clear and unmistakable right to the subject properties. The Court found that petitioner's prayer in the appellate court was merely for the preservation of the status quo, which is a provisional remedy. The Court reiterated that the appellate court's jurisdiction to grant such a writ is limited to actions or proceedings pending before it. Since the principal case (Civil Case No. 00-196) was pending before the RTC, the appellate court lacked the proper venue to issue the injunction sought.
Main Doctrine
An original action for injunction seeking to preserve the status quo pending resolution of a principal case is outside the jurisdiction of the Court of Appeals when the principal case is pending before a Regional Trial Court. The Court of Appeals' jurisdiction to grant a writ of preliminary injunction is limited to actions or proceedings pending before it, or in a petition for certiorari, prohibition, or mandamus under Section 7 of Rule 65.