Makati v. Ygaña
REITERATIONFacts
The Antecedents: The Municipality (now City) of Taguig filed a complaint against the City of Makati, among others, for judicial confirmation of its territory and boundary limits, and declaration of the unconstitutionality of certain Presidential Proclamations, praying for a writ of preliminary injunction. Taguig asserted its territorial boundaries, claiming that portions of Fort Bonifacio, specifically the "Inner Fort" and a 74-hectare farmland area, were part of its territory, contrary to Presidential Proclamations 2475 and 518 which allegedly placed these areas within Makati. Procedural History: The Regional Trial Court (RTC) initially issued a TRO and subsequently a preliminary injunction enjoining Makati from exercising jurisdiction over the 74-hectare area and the "Inner Fort." Makati filed a petition for certiorari with the Court of Appeals (CA), which initially nullified the injunction but later, in a Resolution, reinstated it only with respect to the "Inner Fort," based on Makati's admissions in its original Answer that it was not exercising jurisdiction over the "Inner Fort." This Resolution became final and executory. Later, Makati sought to amend its Answer to allege jurisdiction over certain barangays within the "Inner Fort." The CA, in a subsequent decision, allowed the amendment of the Answer. Subsequently, Makati filed a motion to declare the preliminary injunction over the "Inner Fort" functus officio or to dissolve it, arguing that the amendment of its Answer expunged the admissions that formed the basis of the injunction. The RTC denied this motion, holding that the decision allowing the amendment did not affect the finality of the injunction. The CA affirmed the RTC's denial. The Petition: The City of Makati filed a petition for review on certiorari, seeking the reversal of the CA's decision and resolution, which affirmed the RTC's denial of its motion to declare the preliminary injunction functus officio or to dissolve it.
Issue(s)
Whether the preliminary injunction over the "Inner Fort" has become functus officio or should be dissolved in light of the amendment of Makati's Answer. Whether the Court of Appeals erred in affirming the trial court's denial of Makati's motion to confirm the preliminary injunction as functus officio or, in the alternative, to dissolve the same.
Ruling
The petition is denied. The Court of Appeals' Decision dated January 31, 2005, and Resolution dated July 1, 2005, in CA-G.R. SP No. 79825, are affirmed.
Ratio Decidendi
On the issue of whether the preliminary injunction over the "Inner Fort" has become functus officio or should be dissolved: The Supreme Court held that the amendment of Makati's Answer, even if allowed by a subsequent CA decision (the Dacudao Decision), did not affect the preliminary injunction over the "Inner Fort" which had been reinstated and had attained finality through the Jacinto Resolution. The Court emphasized that the Dacudao Decision dealt with the propriety of admitting the amended Answer, not with the validity of the preliminary injunction itself. The Jacinto Resolution, which reinstated the injunction, was a final adjudication on the propriety of the writ and had become the "law of the case" between the parties. The Court clarified that the amendment of pleadings does not alter the facts contemplated under the "law of the case" doctrine, especially when a judgment has already attained finality. The Court further noted that the reinstatement of the injunction in the Jacinto Resolution was not solely based on Makati's admissions but also on documentary evidence and witness testimonies presented by Taguig, which established Makati's threat to Taguig's rights and its attempt to expand jurisdiction over the "Inner Fort." The preservation of the status quo ante was a primary consideration for the issuance of the injunction, and the amendment of the Answer did not change the established facts that supported the injunction. On the issue of whether the Court of Appeals erred in affirming the trial court's denial of Makati's motion: The Court found no error in the CA's affirmation of the trial court's denial. The CA correctly reasoned that the Dacudao Decision did not invalidate the Jacinto Resolution, which had already become final and executory. The Jacinto Resolution reinstated the preliminary injunction over the "Inner Fort" and, in doing so, affirmed the propriety of its issuance by the trial court, including the grounds supporting it. Therefore, the CA was justified in relying on the trial court's findings and rationalizations in issuing the preliminary injunctive writ concerning the "Inner Fort." The Court reiterated that the "law of the case" doctrine prevents re-litigation of settled issues, and the amendment of Makati's Answer did not constitute a change in facts that would warrant deviating from the established rule of the case. The Court stressed that public policy, judicial orderliness, and economy require stability in final judgments, and a prior decision on a settled issue cannot be erased by merely amending pleadings.
Main Doctrine
The amendment of a party's Answer, even if allowed by a subsequent decision, does not affect a preliminary injunction that has already been reinstated and has attained finality, especially when the subsequent decision explicitly acknowledges the finality of the prior ruling on the injunction. The 'law of the case' doctrine mandates adherence to settled issues, and a change in pleading allegations does not constitute a change in the underlying facts that would warrant overturning a final judgment.