Maunlad Homes v. Union Bank
REITERATIONFacts
The Antecedents: Union Bank of the Philippines (Union Bank) and Maunlad Homes, Inc. (Maunlad Homes) entered into a Contract to Sell for a commercial complex. Maunlad Homes defaulted on its monthly amortizations. Union Bank rescinded the contract and demanded payment and vacation of the property. Union Bank filed an ejectment case, while Maunlad Homes filed an injunction case to prevent Union Bank from collecting rentals from tenants. Procedural History: The injunction case saw the RTC grant a preliminary injunction, which was reversed by the CA. The Supreme Court, in G.R. No. 179898, reinstated the RTC's injunction, finding it premature for the CA to definitively rule on the parties' rights and remanded the case for resolution. The ejectment case saw the MeTC and RTC dismiss the complaint for lack of jurisdiction, but the CA affirmed this. However, the Supreme Court, in G.R. No. 190071, reversed the CA, ruling that the MeTC had jurisdiction and ordered Maunlad Homes to vacate the property and pay rentals. This decision became final and executory. Subsequently, Union Bank moved to dismiss the injunction case as moot, arguing the issues were resolved in G.R. No. 190071. The RTC denied the motion, viewing the ejectment ruling as provisional. The CA reversed the RTC, dismissing the injunction case for being moot. The Petition: Maunlad Homes filed a Petition for Review on Certiorari assailing the CA's dismissal of the injunction case.
Issue(s)
Whether the Court of Appeals correctly dismissed the Complaint for injunction for having been rendered moot by the Supreme Court's Decision in G.R. No. 190071. Whether the Supreme Court's ruling in the ejectment case (G.R. No. 190071) had definitively resolved the issues in the injunction case (G.R. No. 179898).
Ruling
The petition is unmeritorious. The Court of Appeals correctly dismissed the Complaint for injunction for having been rendered moot by the Decision dated August 15, 2012 in G.R. No. 190071.
Ratio Decidendi
On the issue of whether the Court of Appeals correctly dismissed the Complaint for injunction for having been rendered moot by the Supreme Court's Decision in G.R. No. 190071: The Court held that the power of judicial review is limited to actual cases or controversies, which are affected by ripeness and mootness. A case becomes moot and academic when a supervening event renders a judgment unnecessary and superfluous. In the injunction case (G.R. No. 179898), the Court initially found it premature for the CA to rule on Maunlad Homes' right to collect rentals and reinstated the preliminary injunction, remanding the case for trial court resolution to preserve the status quo. On the issue of whether the Supreme Court's ruling in the ejectment case (G.R. No. 190071) had definitively resolved the issues in the injunction case (G.R. No. 179898): The subsequent ruling in the ejectment case (G.R. No. 190071) categorically declared that Maunlad Homes lost its right to possess the property under the Contract to Sell due to default in payments. The Court in G.R. No. 190071 emphasized that the non-payment of the purchase price renders a contract to sell ineffective and without force and effect, thereby depriving the buyer of the right to continue possessing the property. This definitive ruling in the ejectment case rendered any further adjudication in the injunction case unnecessary and superfluous. The main issue in the injunction case, whether Union Bank should be permanently enjoined from collecting rental payments, no longer needed resolution because the Contract to Sell, which was the basis for Maunlad Homes' right to possess and collect rentals, was already determined to be without force and effect. Allowing the RTC to adjudicate the injunction case would risk violating the doctrine of immutability of final judgments, as the Court's definitive judgment in the ejectment case was final and executory. There must be an end to litigation, and the prevailing party should not be denied the fruits of victory by dilatory schemes.
Main Doctrine
A case becomes moot and academic when a supervening event renders a judgment over the issues unnecessary and superfluous, thereby presenting no actual case or controversy. The final and executory ruling in an ejectment case, which declared a contract to sell as ineffective and without force and effect, renders a subsequent injunction case seeking to enforce rights under the same contract moot and academic.