Victorias Milling v. International Pharmaceuticals
REITERATIONFacts
The Antecedents: Victorias Milling Co. (VMC) filed a complaint for unlawful detainer and damages against International Pharmaceuticals, Inc. (IPI) before the Municipal Circuit Trial Court (MCTC). Summons was served on IPI's Human Relations Department Manager. Procedural History: IPI filed an Answer with a reservation regarding the MCTC's jurisdiction over its person due to improper service of summons. IPI moved for the suspension of proceedings, which the MCTC denied, ordering the case to proceed under the Rule on Summary Procedure. IPI's motion for reconsideration was denied. IPI then filed a petition for certiorari with the Court of Appeals (CA) questioning the MCTC's jurisdiction over its person. The Petition: While the certiorari petition was pending before the CA, the MCTC continued with the ejectment proceedings, directing parties to submit affidavits and position papers. The CA, in its assailed Resolution, granted IPI's petition for certiorari, issued a writ of preliminary injunction enjoining the MCTC from proceeding with the ejectment case and disturbing IPI's possession, conditioned upon IPI posting a ₱200,000.00 injunction bond. VMC filed the present petition for certiorari before the Supreme Court, assailing the CA's resolution.
Issue(s)
Whether the Court of Appeals gravely abused its discretion amounting to lack or excess of jurisdiction by ordering the issuance of an injunctive writ on the basis of a petition for certiorari against interlocutory orders in an ejectment suit, which is expressly prohibited. Whether the Court of Appeals gravely abused its discretion by failing to dismiss outright the petition for certiorari against interlocutory orders in an ejectment suit, notwithstanding its express prohibition under the Rules of Court. Whether the Court of Appeals gravely abused its discretion by entertaining the petition for certiorari filed directly with it, disregarding the hierarchy of courts.
Ruling
The Supreme Court granted the petition, nullified and set aside the Resolution of the Court of Appeals dated May 6, 2005, and ordered the Court of Appeals to dismiss the petition for certiorari filed before it.
Ratio Decidendi
On the issue of the Court of Appeals' grave abuse of discretion in issuing an injunctive writ against interlocutory orders in an ejectment suit: The Court held that a petition for certiorari assailing an interlocutory order in an ejectment case is expressly prohibited under Section 13 of Rule 70 of the Rules of Court and the Rule on Summary Procedure. The purpose of these rules is to ensure the expeditious and inexpensive resolution of ejectment cases without regard to technical rules. While the Rule on Summary Procedure permits a motion to dismiss on the ground of lack of jurisdiction over the subject matter, it does not explicitly mention lack of jurisdiction over the person. The principle of expressio unius est exclusio alterius applies, meaning the express mention of one thing implies the exclusion of all others. Therefore, allegations of improper service of summons, without a convincing showing of substantive injustice, cannot be used to hinder proceedings or justify the violation of the prohibition against certiorari petitions. The CA's issuance of the injunctive writ, which effectively stopped the summary proceedings, was contrary to the objective of the Rule on Summary Procedure. On the issue of the Court of Appeals' failure to dismiss the petition outright: The Court reiterated that the petition for certiorari was prohibited. The CA should have dismissed it outright, as entertaining it would lead to delays that the Rule on Summary Procedure aims to prevent. The Court emphasized that IPI had already filed its Answer and participated in the MCTC proceedings, and any errors made by the MCTC could be raised on appeal after the final resolution of the ejectment case. The Court found no procedural void that would justify the CA's action, distinguishing the case from Go v. Court of Appeals where an indefinite suspension of proceedings occurred. On the issue of disregarding the hierarchy of courts: While the petition was filed directly with the CA instead of the RTC, the Court found this issue unnecessary to resolve given its disposition on the primary issue of the prohibited nature of the certiorari petition. However, the Court implicitly addressed this by stating that the CA should have dismissed the petition outright, implying that it should not have entertained it in the first place, regardless of the court level.
Main Doctrine
A petition for certiorari assailing an interlocutory order in an ejectment case, which is mandated to be tried under summary procedure, is expressly prohibited by the Rules of Court and should be dismissed outright by the appellate court, as it contravenes the objective of expeditious and inexpensive resolution of such cases. The alleged improper service of summons, without a showing of substantive injustice, does not justify the violation of this prohibition or the issuance of an injunctive writ that would unduly delay the proceedings.