Julie's Franchise Corp. v. Ruiz
REITERATIONFacts
The Antecedents: Respondent Dancel entered into three franchise agreements with petitioner corporation for bakeshops in Dipolog City and Zamboanga Del Norte. After renewing the agreements and paying renewal fees, petitioner corporation informed respondent Dancel of its decision to terminate the agreements, citing the dissolution of respondent Dancel's business partnership. Procedural History: Respondent Dancel filed a complaint for Specific Performance with a prayer for a Writ of Preliminary Injunction. The trial court initially denied the injunction for lack of jurisdiction. The Court of Appeals, however, granted a Temporary Restraining Order and subsequently a Writ of Preliminary Injunction, holding that the trial court had jurisdiction. This decision became final and executory after petitioner corporation's appeal to the Supreme Court was denied for late filing. Subsequently, the trial court issued a Writ of Preliminary Mandatory and Prohibitory Injunction, directing petitioner corporation to refrain from terminating the agreements, deliver supplies, and allow respondent Dancel to use the trade name and paraphernalia. Petitioner corporation filed several motions, including a motion to lift the injunction and a motion for reconsideration, all of which were denied. Meanwhile, indirect contempt proceedings were filed against petitioners in another branch of the trial court. The Petition: Petitioners filed a petition for certiorari under Rule 65, seeking to annul the Joint Resolution denying their motions and ordering the issuance of the Writ of Preliminary Injunction, alleging that the respondent judge acted without or in excess of jurisdiction or with grave abuse of discretion. They also sought to restrain the judge handling the indirect contempt proceedings.
Issue(s)
Whether the RTC committed grave abuse of discretion in issuing the Writ of Preliminary Injunction for acts committed outside its territorial boundaries. Whether the RTC committed grave abuse of discretion in granting the injunction despite the alleged absence of a right in esse and the expiration of the contracts. Whether the issues regarding summary judgment and intellectual property rights are proper subjects for a Rule 65 petition. Whether the indirect contempt charges in a separate RTC branch can be enjoined via this petition.
Ruling
The petition is dismissed. The Supreme Court found no grave abuse of discretion on the part of the trial court in issuing the Writ of Preliminary Injunction, as it was merely complying with the final and executory decision of the Court of Appeals. Issues pertaining to errors of judgment, such as dismissal on summary judgment or granting/denying injunctions based on the merits, are not reviewable in a certiorari proceeding. The issue concerning indirect contempt, being from a separate case in a different branch, was also deemed improper for inclusion in the certiorari petition.
Ratio Decidendi
On Issue 1: The Court ruled that there was no grave abuse of discretion on the part of the trial court in issuing the Writ of Preliminary Injunction. The trial court merely followed the directive of the Court of Appeals (CA) in CA-G.R. SP No. 00740, which had already attained finality. Under the doctrine of immutability of judgment, a final decision can no longer be modified, even to correct perceived errors of law. Since the CA had already determined that the trial court had the authority to issue the injunction because the effects of the termination were felt within its territorial limits, that determination is now binding. Any attempt to relitigate this jurisdictional point is barred by the finality of the previous proceedings. On Issue 2: The Court found no merit in the argument that the injunction was improper due to the expiration of contracts or lack of a right in esse. These substantive issues were already addressed by the CA when it ruled that Dancel's right to the writ was clear, particularly since JFC had already accepted franchise fees for the five-year period from 2004 to 2009. The RTC was bound by the CA’s finding that the pre-termination by JFC warranted the issuance of the writ. To deviate from this would have been an error on the part of the RTC in failing to execute a final appellate order. Consequently, the trial court's adherence to the CA's final mandate cannot constitute grave abuse of discretion. On Issue 3: The Court clarified that JFC's arguments regarding the denial of summary judgment and the protection of its intellectual property rights involved errors of judgment, not errors of jurisdiction. A petition for certiorari is a narrow remedy limited to resolving jurisdictional matters. Errors of judgment, which involve the court's appreciation of evidence or conclusions of law, must be corrected through an ordinary appeal under Rule 45, not Rule 65. Because the facts alleged by JFC did not raise genuine jurisdictional issues but rather questioned the trial court's legal reasoning, the petition was found to be devoid of merit on these counts. On Issue 4: The Court held that it was improper to include the issue of the indirect contempt charge in this petition. The contempt case was a separate proceeding handled by a different branch (RTC Branch 9) from the one that issued the assailed injunction (RTC Branch 10). Challenges to the actions of RTC Branch 9 should have been the subject of a separate petition for prohibition rather than being bundled into a certiorari petition against RTC Branch 10. The Court thus refrained from resolving the eighth issue as it was procedurally misplaced and beyond the scope of the current action.
Main Doctrine
A petition for certiorari under Rule 65 is intended to correct errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction, and it is not a remedy to correct errors of judgment. A judgment that has attained finality can no longer be modified, except to correct clerical errors.