Metro Rail Transit Development v. Trackworks Rail Transit Advertising
REITERATIONFacts
The Antecedents: The Department of Transportation and Communication (DOTC), Metro Rail Transit Corporation Limited (MRT), and Metro Rail Transit Development Corporation (MRTDC) entered into agreements granting MRTDC rights to develop commercial premises, lease, sublease, assign interests, and obtain income and advertising rights related to the MRT-3 Light Rail System. On October 27, 1998, MRTDC contracted with Trackworks Rail Transit Advertising, Vending and Promotions, Inc. (Trackworks) for advertising services for five years, with Trackworks obligated to pay a percentage share of gross revenues or a minimum guaranty. This contract was renewed on March 11, 2005, extending its effectivity to December 31, 2015, with increased payments. Trackworks defaulted in its payments, owing MRTDC P276,978,072.42 as of February 28, 2009. MRTDC sent a demand letter, and upon Trackworks' failure to fully pay, MRTDC sent a Notice of Termination on September 1, 2009. Procedural History: Trackworks filed a Complaint with Application for Temporary Restraining Order (TRO) and/or Writ of Preliminary Injunction against MRTDC with the RTC of Pasig City (Civil Case No. 77291-PSG), praying for arbitration and to restrain MRTDC from terminating the contract. The RTC Pasig denied the injunction but ordered arbitration and stayed its proceedings. MRTDC later demanded post-termination obligations, prompting Trackworks to file further motions for injunctive relief, which were denied. Trackworks then filed a Notice of Arbitration. Subsequently, Trackworks filed a Petition for Certiorari, Prohibition and Mandamus under Rule 65 with the RTC of Makati City (Civil Case No. 10-414), seeking to restrain MRTDC and Media Puzzle Inc. (MPI) from circulating termination documents and appointing a new agent, and to prohibit the DOTC from issuing permits to MRTDC and MPI. The RTC Makati granted a TRO and later, through its October 22, 2010 Omnibus Order and December 20, 2010 Order, denied MRTDC's Motion to Dismiss and effectively granted Trackworks' application for a writ of preliminary injunction. Meanwhile, the RTC Pasig denied Trackworks' motion for reconsideration. MRTDC filed a Petition for Certiorari with the Court of Appeals (CA) assailing the Makati RTC's orders. The CA initially granted MRTDC's petition, annulling the Makati RTC's orders and dismissing Civil Case No. 10-414, citing violation of the doctrine of judicial stability and litis pendentia. However, upon Trackworks' motion for reconsideration, the CA reversed its decision, dismissing MRTDC's petition for certiorari as moot due to the Makati RTC's June 14, 2012 Decision which made the preliminary injunction permanent. The CA reasoned that an appeal was the proper remedy after the RTC Makati's decision. MRTDC then filed the present Petition for Review on Certiorari under Rule 45. The Petition: MRTDC challenges the CA's November 9, 2012 Resolution, arguing that the RTC Makati's June 14, 2012 Decision was not yet final and executory when the CA rendered its July 30, 2012 Decision, and that certiorari was the proper remedy as the Makati RTC acted without jurisdiction. Trackworks argues that the CA correctly dismissed the certiorari petition as moot because the RTC Makati's June 14, 2012 Decision provided an adequate remedy (appeal), rendering certiorari superfluous.
Issue(s)
Whether the Petition for Certiorari filed by MRTDC before the CA has been rendered moot by reason of the June 14, 2012 Decision of the RTC of Makati City, Branch 65. Whether the RTC of Makati City, Branch 65, acted without or in excess of jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction, in issuing its assailed orders and decision, thereby violating the doctrine of judicial stability and the rule on litis pendentia.
Ruling
The Petition is granted. The November 9, 2012 Resolution of the Court of Appeals is reversed and set aside. The Decision dated June 14, 2012 rendered by the Regional Trial Court of Makati City, Branch 65 in Civil Case No. 10-414, the proceedings therein and all orders issued, are declared NULL and VOID for lack of jurisdiction.
Ratio Decidendi
On the mootness of the certiorari petition: The Supreme Court held that while generally, the promulgation of a decision on the merits renders a certiorari petition moot, this rule admits exceptions. In this case, the assailed orders and decision of the RTC of Makati City were considered null and void for lack of jurisdiction. Therefore, the fact that the RTC Makati rendered a decision on the merits did not cure the jurisdictional defect. The Court found that the RTC Makati violated the doctrine of judicial stability by interfering with the orders of a co-equal court, the RTC of Pasig City. The petition before the RTC Makati should have been dismissed for lack of jurisdiction, rendering its subsequent orders and decision void. Thus, the CA erred in dismissing the certiorari petition solely on the ground of mootness without addressing the jurisdictional infirmity. On the violation of the doctrine of judicial stability and litis pendentia: The Supreme Court ruled that the RTC of Makati City violated the doctrine of judicial stability by taking cognizance of Trackworks' Petition for Certiorari, Prohibition and Mandamus. This petition involved the same parties and subject matter that were already under the jurisdiction of the RTC of Pasig City, which had previously denied the injunctive relief sought by Trackworks. The RTC Makati had no authority to nullify the orders of the RTC Pasig, a coordinate and co-equal court. Consequently, the proceedings and decision of the RTC Makati were void for lack of jurisdiction. Furthermore, the Court found the existence of litis pendentia, as there was an identity of parties (or at least substantial identity of interests), rights asserted, and reliefs prayed for, between the case before the RTC Pasig and the case before the RTC Makati. The judgment in one case would amount to res judicata in the other. The petition before the RTC Makati was therefore unnecessary and vexatious, and should have been dismissed on this ground as well.
Main Doctrine
A court that renders a judgment without jurisdiction is null and void and may be attacked anytime. Such a judgment creates no rights and produces no effect. Furthermore, a petition for certiorari will not lie if an adequate remedy, such as an appeal, is available, unless an exception applies, such as when the orders complained of are completely null and void.