Golden Cane Furniture Manufacturing Corporation v. Steelpro Philippines
REITERATIONFacts
The Antecedents: Golden Cane Furniture Manufacturing Corporation filed a petition for corporate rehabilitation with the Regional Trial Court (RTC) of San Fernando, Pampanga. The RTC initially issued a Stay Order and set a hearing. However, the RTC later denied due course to the petition, citing grounds such as litis pendentia and forum shopping due to a prior petition for suspension of payments, the rehabilitation receiver's failure to fulfill her duties, failure to file her bond on time, and failure to submit interim financial statements. Consequently, the RTC dismissed the petition and lifted the Stay Order. Procedural History: Following the RTC's dismissal of its petition for corporate rehabilitation and denial of its motion for reconsideration, Golden Cane elevated the matter to the Court of Appeals (CA) through a petition for certiorari. The CA, however, dismissed Golden Cane's petition outright, holding that certiorari was the incorrect remedy. The CA ruled that a petition for review under Rule 43 of the Rules of Court was the proper mode of appeal, as per A.M. No. 04-9-07-SC. Golden Cane's subsequent motion for reconsideration of the CA's dismissal was also denied, leading to the present petition. The Petition: Golden Cane Furniture Manufacturing Corporation seeks review on certiorari of the CA's resolutions, arguing that the CA erred in dismissing its petition. Golden Cane contends that A.M. No. 08-10-SC (the 2008 Rules of Procedure on Corporate Rehabilitation) superseded A.M. No. 04-9-07-SC. It asserts that under Rule 8 of the 2008 Rules, an order denying due course to a rehabilitation petition before the plan's approval is not appealable under Rule 43, and the appropriate remedy is a petition for certiorari under Rule 65. Golden Cane maintains that its case falls under the 2008 Rules, making certiorari the correct recourse.
Issue(s)
Whether the correct remedy to challenge the outright dismissal of Golden Cane's petition for rehabilitation is a petition for review under Rule 43 or a petition for certiorari under Rule 65 of the Rules of Court.
Ruling
The Supreme Court affirmed the Court of Appeals' ruling, holding that the petition for certiorari was the wrong mode of appeal. The Court denied the petition.
Ratio Decidendi
On Issue 1: The Supreme Court affirmed the CA's ruling that a petition for review under Rule 43 was the correct remedy, not a petition for certiorari under Rule 65. The Court explained that a corporate rehabilitation case is a special proceeding, and the dismissal of the petition for rehabilitation is a final order that finally disposes of the case. Pursuant to A.M. No. 04-9-07-SC, all decisions and final orders in cases governed by the Interim Rules of Procedure on Corporate Rehabilitation are appealable to the Court of Appeals through a petition for review under Rule 43. Golden Cane's petition for rehabilitation was filed under the regime of the Interim Rules, as the initial hearing occurred before the effectivity of the 2008 Rules, and the transitory provision of the 2008 Rules indicated that pending petitions not yet past the initial hearing would be governed by the Interim Rules unless otherwise ordered. Therefore, the dismissal order was a final order under the Interim Rules, making Rule 43 the appropriate mode of appeal. Even if the 2008 Rules were considered applicable, the outright dismissal of the petition could be equated to the disapproval of the rehabilitation plan, which Section 2 of Rule 8 of the 2008 Rules states can only be reviewed through a petition for review under Rule 43. The Court emphasized that a petition for certiorari under Rule 65 is generally reserved for orders issued after the approval of the rehabilitation plan under the 2008 Rules, or for any order issued after the approval of the Rehabilitation Plan under the 2013 Rules, which was not the situation in this case. The Court concluded that the CA correctly dismissed Golden Cane's petition for certiorari for being the wrong mode of appeal.
Main Doctrine
The Supreme Court clarified that the proper remedy to challenge the outright dismissal of a petition for corporate rehabilitation, filed under the Interim Rules of Procedure on Corporate Rehabilitation, is a petition for review under Rule 43 of the Rules of Court, not a special civil action for certiorari under Rule 65. This is because such dismissal is considered a final order disposing of the case, and A.M. No. 04-9-07-SC mandates a petition for review for all decisions and final orders in cases governed by the Interim Rules. Even if the 2008 Rules were applicable, an outright dismissal would be treated similarly to the disapproval of a rehabilitation plan, still requiring a petition for review under Rule 43.