Trajano v. Uniwide Sales Warehouse Club
REITERATIONFacts
1. The Antecedents: Uniwide Sales Warehouse Club, Inc. (Uniwide) entered into a sales arrangement with Golden Sea Overseas Sales Corp. (Golden Sea) and Juan Trajano (petitioner) for the importation of goods from China in 2001. Uniwide alleged that Trajano guaranteed the payment for the goods, and Uniwide issued post-dated checks to Trajano and Vicente Kua, with face values including a 36% annual interest. From January 2002, Golden Sea delivered P178,199,054.60 worth of unsaleable, defective, or un-ordered goods. Despite Uniwide's request for a credit of P163,199,054.60, Golden Sea and Trajano encashed P86,284,028.00 of the post-dated checks. Uniwide filed a complaint for a sum of money and damages, seeking a refund for the problematic goods and an injunction against the encashment of remaining checks. 2. Procedural History: The case was filed before the Regional Trial Court (RTC) of Parañaque, which issued a preliminary injunction against Trajano. Trajano moved to post a counterbond to lift the injunction, which Uniwide opposed, moving for an ocular inspection of the goods. The RTC sustained the injunction, granted the ocular inspection, and deferred the resolution of Trajano's motion to post a counterbond. Trajano sought partial reconsideration, arguing the contract of sale of goods was separate from the contract of loan for payment. Both Trajano and Golden Sea moved for the inhibition of the presiding judge, who eventually recused himself. The case was re-raffled, but the RTC deferred further proceedings due to a pending petition for certiorari before the Court of Appeals (CA) concerning the judge's inhibition. Trajano then filed his own petition for certiorari with the CA, assailing the RTC's interlocutory orders deferring the resolution of his motions. The CA upheld the RTC's deferral, citing judicial courtesy. Trajano's subsequent motion for reconsideration was denied, leading to the present petition for review on certiorari before the Supreme Court. 3. The Petition: Petitioner Juan Trajano, through a petition for review on certiorari under Rule 45, challenges the CA's decision and resolution that upheld the RTC's deferral of his motions to post a counterbond and for partial reconsideration. Trajano argues that the RTC should have resolved his motions, as the propriety of a judge's inhibition does not affect the court's jurisdiction. He contends that the CA erred in applying the principle of judicial courtesy. Uniwide, in its comment, argues that Trajano improperly availed of a Rule 45 petition, that the petition lacks proper verification, and that the issue is moot and academic because a prior CA decision had already dissolved the preliminary injunction against Trajano encashing the checks. The Supreme Court, in its decision, declared the issue of the counterbond and reconsideration moot and academic, noting the prior dissolution of the injunction, but ordered the RTC to continue with the proceedings in the main case.
Issue(s)
(1) Whether the petition should be denied outright for procedural infirmities, specifically: (a) lack of proper verification; and (b) improper remedy (Rule 45 petition). (2) Whether the resolution of Trajano's motion to post counterbond, motion for partial reconsideration, and supplemental motion is already moot and academic. (3) Whether the CA erred in not finding that the RTC committed grave abuse of discretion in suspending the proceedings in Civil Case No. 05-0265.
Ruling
The Supreme Court partly granted the petition. It declared the resolution of Trajano's motion to post counterbond, motion for partial reconsideration, and supplemental motion as moot and academic. It ordered the Regional Trial Court of Parañaque - Branch 195 to continue with the proceedings in Civil Case No. 05-0265.
Ratio Decidendi
On Issue (1): Procedural Infirmities: The Court found the petition not procedurally infirm. Regarding verification, it noted that Trajano provided competent evidence of identity (Passport No. XX041470) and considered the failure to furnish a copy with such evidence a minor error curable in the interest of substantial justice, citing precedents where procedural rules were relaxed for substantial compliance. Concerning the remedy, the Court clarified that Trajano's petition for review on certiorari under Rule 45 was proper as it assailed the CA's final order regarding the RTC's interlocutory orders, which were themselves correctly assailed before the CA via a petition for certiorari for alleged grave abuse of discretion. On Issue (2): Mootness of Motions: The Court declared the issue of Trajano's motions to post counterbond and for partial reconsideration moot and academic. It highlighted that the writ of preliminary injunction enjoining Trajano from encashing the post-dated checks had already been dissolved with finality by the CA in a previous case (CA-G.R. SP No. 93492). Since the injunction was already lifted, Trajano could no longer seek substantial relief from his motions filed to dissolve it. Furthermore, the Court noted that Trajano himself admitted the checks had become stale, rendering them valueless and unpayable. On Issue (3): Grave Abuse of Discretion and Judicial Courtesy: The Court ruled that the CA erred in applying the principle of judicial courtesy to suspend the RTC proceedings. It explained that the pendency of a certiorari petition does not automatically interrupt lower court proceedings unless a TRO or injunction is issued by the higher court. While judicial courtesy can justify suspension, its application is limited to situations where there is a strong probability that the higher court's issue would be rendered moot by the continuation of lower court proceedings. The Court found no such strong probability regarding the issue of the judge's inhibition. Moreover, it emphasized that jurisdiction vests in the court, not the judge, and that different branches of the RTC are coordinate and co-equal, meaning proceedings can continue before another branch even if a judge inhibits himself. Therefore, the RTC's suspension of proceedings was not justified by judicial courtesy and did not involve jurisdictional error.
Main Doctrine
The pendency of a special civil action for certiorari before a higher court does not automatically interrupt the proceedings in the lower court unless a temporary restraining order or a writ of preliminary injunction is issued by the higher court. The principle of judicial courtesy, while applicable in certain instances, is an exception rather than the rule and should not be applied if it would render the issue before the higher court moot and academic.