Wee v. Wee
REITERATIONFacts
The Antecedents: The core of this dispute lies in a conflict between two factions of stockholders vying for control of Rico Philippines Industrial Corporation (RPIC), a company involved in the export of seaweeds. The corporation's bylaws mandate an annual stockholders' meeting on the first Friday of May. For years, the family of petitioner Lee Hiong Wee managed RPIC, with Lee Hiong Wee serving as president and chairman of the board. This established management structure was challenged in July 2003 when a group led by Dee Ping Wee and the late Mario T. Tan (husband of respondent Marina Tan) filed a petition with the Securities and Exchange Commission (SEC) seeking the holding of a long-overdue annual stockholders' meeting. Procedural History: The SEC granted the petition, ordering a meeting to be held by October 30, 2003. This meeting occurred on October 9, 2003, resulting in the election of a new board of directors largely aligned with the Dee Ping group, and the replacement of Lee Hiong Wee as president and chairman. Subsequently, the Lee Hiong group filed a complaint with the Regional Trial Court (RTC) of Imus, Cavite, seeking to nullify the SEC-ordered meeting and subsequent changes. The RTC issued a temporary restraining order (TRO) preserving the status quo. This TRO was challenged in the Court of Appeals (CA) by the Dee Ping group. Following recusal of the initial RTC judge, the case was re-raffled. The CA, in a subsequent decision, directed the RTC to conduct an inventory and devise means to protect corporate assets. The RTC, through a different judge, then issued a preliminary mandatory injunction, ordering the Dee Ping group to cease their functions and revert to the prior status quo, and to surrender control of the plant. The Dee Ping group again petitioned the CA, leading to a resolution that effectively halted the enforcement of the RTC's injunction and restored the status quo ante. The CA later issued a decision nullifying the RTC's writ of preliminary mandatory injunction. The Petition: Petitioner Lee Hiong Wee, through a petition for review under Rule 45 of the Rules of Court, assails the Court of Appeals' decision dated May 14, 2004. He argues that the CA Second Division acted with grave abuse of discretion, exceeding its jurisdiction by taking cognizance of a case already pending before another division (litis pendentia) and by issuing a TRO with undue haste on a moot issue. Petitioner also contends that the respondents engaged in forum shopping by filing multiple suits involving the same essential facts and circumstances. He further claims the CA's decision departed from accepted judicial proceedings and was based on a contrived ratio decidendi, particularly in its handling of the TRO and the consolidation of cases. The petition seeks the nullification of the CA's decision.
Issue(s)
Whether the Court of Appeals (Second Division) committed grave abuse of discretion in issuing a TRO and subsequently nullifying the RTC's writ of preliminary mandatory injunction. Whether the CA Second Division acted with undue haste in issuing the TRO. Whether the CA Second Division issued the TRO on a moot and academic matter. Whether the CA Second Division acted without jurisdiction due to litis pendentia and forum shopping. Whether the RTC judge committed grave abuse of discretion in issuing the writ of preliminary mandatory injunction.
Ruling
The Supreme Court denied the petition and affirmed the assailed Decision and Resolution of the Court of Appeals. The Court found no grave abuse of discretion on the part of the CA and held that the RTC judge acted with grave abuse of discretion in issuing the writ of preliminary mandatory injunction.
Ratio Decidendi
On the alleged grave abuse of discretion by the CA Second Division: The Court found no grave abuse of discretion in the CA's issuance of the TRO. The CA correctly nullified the RTC's writ of preliminary mandatory injunction. On the alleged undue haste by the CA Second Division: The Court found no undue haste in the CA's issuance of the TRO. It noted that the RTC judge issued a TRO on the same day the complaint was filed, whereas the CA issued its TRO ten days after the petition was filed. On the alleged mootness of the TRO: The Court clarified that the Sheriff's Report indicated the writ was only partially satisfied, not that the matter was moot and academic, refuting the petitioner's claim of mootness. On the alleged lack of jurisdiction due to litis pendentia and forum shopping: The Court held that the filing of CA-G.R. SP No. 82569 during the pendency of CA-G.R. SP No. 79988 did not constitute forum shopping. The Court explained that the issues and reliefs sought in the two cases were significantly different. CA-G.R. SP No. 79988 questioned Judge Quisumbing's TRO, while CA-G.R. SP No. 82569 questioned Judge Mangrobang's writ of preliminary mandatory injunction. Furthermore, a judgment in CA-G.R. SP No. 79988 would not amount to res judicata in CA-G.R. SP No. 82569. On the RTC judge's alleged grave abuse of discretion in issuing the writ of preliminary mandatory injunction: The Court found that the RTC judge's writ of preliminary mandatory injunction was issued with grave abuse of discretion. The writ went beyond restoring the status quo and included mandatory commands for the delivery of physical possession of the plant premises and assistance from the PNP, which the CA found to be an improper use of such injunction.
Main Doctrine
The Supreme Court affirmed the Court of Appeals' decision nullifying a writ of preliminary mandatory injunction issued by the Regional Trial Court, finding that the RTC judge acted with grave abuse of discretion. The Court also clarified that the filing of a subsequent petition with a different Court of Appeals division did not constitute forum shopping, as the issues and reliefs sought were distinct, and a judgment in the earlier case would not result in res judicata.