Casupanan v. Fugoso
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the lawful occupancy of market stalls, specifically stalls Nos. 280-283 in the Quinta Market, City of Manila. The petitioner, Maria Casupanana, claimed to be the occupant and sought to prevent her ejection and disturbance by city officials. The respondent, Albina Elizaga, was later determined by the lower court to be the former lawful occupant based on market resolution rules. 2. Procedural History: The petitioner initially filed a complaint in the Manila Court of First Instance (Case No. 1181) seeking a declaration of her lawful occupancy of the market stalls and an injunction against city officials from ejecting her. The respondent Judge Emilio Peña presided over this case. After the court refused to issue a preliminary injunction, a decision on the merits was rendered, adjudging Albina Elizaga as the lawful occupant. The petitioner then filed the instant petition with the Supreme Court. 3. The Petition: The petitioner seeks a writ of inhibition against the respondent Mayor Valeriano Fugoso, Judge Emilio Peña, and other city officials, to prevent them from enforcing the decision and from further proceedings in the main case. She also requested a preliminary injunction. The petitioner argued that the respondent Judge abused his discretion by not deciding on the preliminary injunction and by proceeding to a decision on the merits after a delay. The respondents countered that the preliminary injunction was denied due to insufficient grounds and the circumstances of the case. The Supreme Court noted that the main case had been decided on the merits, rendering the petition unnecessary, and that the petitioner could seek ancillary relief on appeal.
Issue(s)
Whether the respondent Judge committed grave abuse of discretion in denying the petitioner's prayer for a preliminary injunction. Whether the petition for certiorari is the proper remedy given that the main case has already been decided on the merits and the remedy of appeal is available.
Ruling
The petition is dismissed. The Supreme Court found no grave abuse of discretion on the part of the respondent Judge in refusing to issue the writ of preliminary injunction. Furthermore, with the main case having been decided on the merits, the remedy of appeal became available to the petitioner, rendering the present petition unnecessary.
Ratio Decidendi
On Issue 1: The Court found no showing of grave abuse of discretion on the part of the respondent Judge in refusing to issue the writ of preliminary injunction. The respondents' answer indicated that the court was not convinced of sufficient grounds for its issuance, considering the circumstances and the opposition filed. The facts found in the decision on the merits, which established Albina Elizaga as the legal occupant based on Resolution No. 50 and her timely application and adjudication, fully justified the denial of the preliminary injunction. The petitioner also failed to present any application for the lease of the stalls during the prescribed period under Resolution No. 50. On Issue 2: The Court noted that the main case had already been decided on the merits. This development rendered the petition for certiorari unnecessary, as the petitioner now had the remedy of appeal. If the petitioner remained dissatisfied with the decision on the merits, she could file an appeal with the appellate court and, if desired, seek a preliminary injunction or other ancillary processes from that court. The Supreme Court reiterated that certiorari under Rule 65 is a remedy of last resort, typically employed when ordinary appeal is not available or is insufficient, and only when there is a clear showing of grave abuse of discretion, capricious, or arbitrary exercise of power.
Main Doctrine
A petition for certiorari under Rule 65 of the Rules of Court is not the proper remedy to assail the denial of a preliminary injunction, especially when the denial does not constitute grave abuse of discretion amounting to lack of jurisdiction. The appropriate recourse is to proceed with the trial on the merits and, if dissatisfied with the final judgment, to avail of the remedy of appeal. The Supreme Court will not interfere with the lower court's discretion in granting or denying injunctive relief unless there is a clear showing of grave abuse of discretion.