Republic v. Coalbrine
REITERATIONFacts
The Antecedents: The Export Processing Zone Authority (EPZA), now the Philippine Economic Zone Authority (PEZA), owned the Bataan Hilltop Hotel and Country Club. On August 4, 1994, EPZA entered into a contract with Coalbrine International Philippines, Inc. (Coalbrine) for the rehabilitation and lease of the hotel for twenty-five years, renewable for another twenty-five years. Sheila F. Neri was the Managing Director of the hotel. On July 11, 1996, PEZA rescinded the contract due to Coalbrine's alleged violations and non-performance, subsequently demanding that Coalbrine vacate and pay outstanding obligations. Procedural History: On April 3, 1998, Coalbrine filed a complaint for specific performance and injunction against PEZA in the RTC of Manila, seeking to nullify the contract rescission and prevent PEZA from taking over the hotel. Separately, on April 24, 2002, Coalbrine and Neri filed a complaint for damages and injunction against Zone Administrator Dante M. Quindoza in the RTC of Balanga, Bataan, alleging harassment, obstruction of access, and water disconnection. Quindoza filed a motion to dismiss, which the RTC denied. Quindoza's motion for reconsideration was also denied. The Republic of the Philippines, represented by Quindoza, then filed a petition for certiorari with the Court of Appeals (CA) challenging the RTC orders. The CA denied this petition. The Republic of the Philippines is now before the Supreme Court via a petition for review on certiorari. The Petition: The petitioner, Republic of the Philippines, seeks review on certiorari of the CA's decision. The sole issue raised is respondent Neri's alleged lack of proof of authority to file the complaint in the RTC of Balanga, Bataan, on behalf of Coalbrine. Petitioner argues that Neri is not a real party-in-interest and that her signature on the verification and certification against non-forum shopping was defective, rendering the complaint fatally defective. Petitioner contends that the RTC committed grave abuse of discretion in denying the motion to dismiss, justifying the certiorari petition to the CA and subsequently this petition to the Supreme Court.
Issue(s)
Whether the Republic of the Philippines has the personality to file the petition for review. Whether the denial of the motion to dismiss, an interlocutory order, can be the subject of a petition for certiorari. Whether respondent Sheila F. Neri had the authority to file the complaint and sign the verification and certification against non-forum shopping on behalf of respondent Coalbrine International Philippines, Inc. Whether respondent Neri is a real party-in-interest with a cause of action against the petitioner.
Ruling
The petition is GRANTED. The Decision of the Court of Appeals is REVERSED and SET ASIDE. The Complaint in Civil Case No. 548-ML pending in the Regional Trial Court, Branch 4, Balanga, Bataan, is ordered DISMISSED.
Ratio Decidendi
On the personality of the Republic of the Philippines to file the petition: The Court held that the Republic has the personality to file the petition because Administrator Quindoza was sued for damages for acts allegedly committed in his official capacity as Zone Administrator. Therefore, the complaint against him, in essence, constitutes a suit against the State. On the propriety of a petition for certiorari assailing the denial of a motion to dismiss: While the general rule is that the denial of a motion to dismiss is an interlocutory order and not appealable, and the proper recourse is to file an answer and proceed to trial, this rule is not absolute. The Supreme Court has allowed a writ of certiorari when the appeal does not constitute a speedy and adequate remedy, when the orders were issued in excess of or without jurisdiction or with grave abuse of discretion, for special considerations like public welfare or policy, when the decision in the certiorari case will avoid future litigation, or when the order is a patent nullity. In this case, the RTC's denial of the motion to dismiss was deemed tainted with grave abuse of discretion. On respondent Neri's authority to file the complaint and sign the verification and certification against non-forum shopping: The Court found the certification signed by respondent Neri to be defective because her authority to file the complaint on behalf of Coalbrine had not been proven. The certification did not state that she was authorized by the corporate secretary, and more importantly, there was no showing of a valid board resolution authorizing the corporate secretary to file the action or to authorize Neri. Such proof of authority was not submitted even belatedly. The Court reiterated that only individuals vested with authority by a valid board resolution may sign the certificate of non-forum shopping on behalf of a corporation, and proof of such authority must be attached. Failure to provide this proof is a ground for dismissal. On respondent Neri being a real party-in-interest with a cause of action: The Court found the RTC in error for concluding that respondent Neri had a cause of action. A reading of the allegations in the complaint showed that the acts complained of solely affected the hotel's operations, where Neri was the Managing Director. Her interest in the suit was deemed incidental. Therefore, respondent Neri, as an individual, had no cause of action against the petitioner, and the plaintiff in the case would only be respondent Coalbrine. Consequently, the complaint, as filed by Neri, was fatally defective for lack of authority and for not being prosecuted in the name of the real party-in-interest.
Main Doctrine
A certification against non-forum shopping signed by a person on behalf of a corporation, which is unaccompanied by proof that the signatory is authorized to file the complaint, is a ground for dismissal of the case. The relaxation of this rule requires special circumstances or compelling reasons, and subsequent compliance with proof of authority.