Allgemeine-Bau-Chemie Phils. v. Metropolitan Bank & Trust
REITERATIONFacts
1. The Antecedents: Asian Appraisal Holdings, Inc. (AAHI) obtained a substantial loan from Solidbank Corporation, secured by a real estate mortgage over lots and a condominium building. Petitioner, Allgemeine-Bau-Chemie Phils., Inc., entered into contracts to sell with AAHI for specific condominium units and parking slots, making full payment by October 2001. Subsequently, AAHI defaulted on its loan, leading to the extra-judicial foreclosure of the mortgaged properties by Metropolitan Bank & Trust Co. (Metrobank), which had integrated Solidbank's banking operations. 2. Procedural History: Following the foreclosure sale where Metrobank emerged as the highest bidder, Metrobank filed an ex-parte petition for a writ of possession, which was granted by the Regional Trial Court (RTC) of Muntinlupa City, Branch 276. Concurrently, AAHI had filed a separate complaint against Solidbank seeking to enjoin the foreclosure. Petitioner attempted to intervene in AAHI's case and also filed its own petition with the Court of Appeals (CA) seeking a temporary restraining order and preliminary injunction to prevent Metrobank from taking possession. The CA initially issued a TRO but later denied the preliminary injunction, finding that petitioner had not established a clear right to the properties. The denial of petitioner's motion for reconsideration by the CA led to the present petition. 3. The Petition: Petitioner seeks a review of the CA's decision denying its prayer for a writ of preliminary injunction. Petitioner argues that the CA committed grave error in its denial. However, the Supreme Court finds that the petition before the CA was an original action for injunction, which falls outside the CA's original jurisdiction, as the underlying case was pending before an RTC. The Court also notes that an order granting or denying a preliminary injunction is generally not appealable. Therefore, the petition is denied for want of jurisdiction and for being the wrong procedural vehicle.
Issue(s)
Whether the Court of Appeals has original jurisdiction to issue a writ of preliminary injunction in an action pending before a Regional Trial Court of equal rank. Whether the petition filed before the Court of Appeals was properly framed as a petition for certiorari or prohibition alleging grave abuse of discretion by the Regional Trial Court.
Ruling
The petition is DENIED. The Court of Appeals correctly denied ABCPI's prayer for a writ of preliminary injunction for want of jurisdiction. The Supreme Court affirmed the decision of the Court of Appeals.
Ratio Decidendi
On Issue 1: The Court held that the Court of Appeals' original jurisdiction to grant a writ of preliminary injunction is limited to actions or proceedings pending before it. Section 2 of Rule 58 of the Rules of Court clearly provides that a preliminary injunction may be granted by the court where the action or proceeding is pending. In this case, ABCPI's complaint-in-intervention in Civil Case No. 00-196 was pending before Branch 256 of the Muntinlupa RTC, not with the Court of Appeals. Therefore, the appellate court lacked the original jurisdiction to issue the injunction sought by ABCPI. The Court reiterated that an original action for injunction is outside the appellate court's original jurisdiction, which is limited to actions for annulment of judgments of RTCs and specific writs like mandamus, prohibition, certiorari, habeas corpus, and quo warranto, as provided by B.P. 129. On Issue 2: The Court found that ABCPI's petition before the Court of Appeals was an original action for preliminary injunction, seeking to preserve the status quo. However, for the Court of Appeals to have jurisdiction over such a petition to enjoin a lower court's action, it must be framed as a petition for certiorari or prohibition under Rule 65 of the Rules of Court. This requires alleging that the RTC acted without or in excess of its jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction. The petition filed by ABCPI did not sufficiently allege, much less demonstrate, such grave abuse of discretion on the part of the Muntinlupa RTC in issuing the writ of possession. Consequently, for want of jurisdiction, the petition before the appellate court should have been dismissed outright. The Court also noted that an order granting or denying a preliminary injunction is generally not appealable.
Main Doctrine
The Supreme Court affirmed the appellate court's denial of a petition for injunction, holding that the Court of Appeals lacks original jurisdiction to issue a writ of preliminary injunction in an action that is not pending before it. The Court emphasized that the jurisdiction to grant such a remedy lies with the court where the principal action is pending, as provided by Section 2 of Rule 58 of the Rules of Court. Furthermore, the Court clarified that a petition before the appellate court seeking to enjoin a lower court's action must be framed as a petition for certiorari or prohibition under Rule 65, alleging that the lower court acted without or in excess of jurisdiction, or with grave abuse of discretion, which was not sufficiently alleged in the petitioner's case.