Case Digest (G.R. No. 128349)
Facts:
Bachrach Corporation v. The Honorable Court of Appeals and Philippine Ports Authority, G.R. No. 128349, September 25, 1998, Supreme Court First Division, Vitug, J., writing for the Court. Bachrach filed a petition for review on certiorari under Rule 45 contesting the Court of Appeals' decision in CA-G.R. SP No. 38763 (promulgated 12 November 1996) which had nullified certain Regional Trial Court orders and ordered dismissal of Bachrach's Civil Case No. 95-73399.Bachrach had two 99-year leases (Blocks 180 and 185) for parcels in the Manila Port Area. After Executive Order No. 321 transferred administration of the Port Area to PPA, PPA raised rent by about 1,500%, which Bachrach refused to pay. PPA filed an unlawful detainer action in the Metropolitan Trial Court (MeTC), Civil Case No. 138838, on 23 March 1992. The MeTC ruled for eviction on 27 April 1993; the Manila RTC affirmed on 21 September 1993; the Court of Appeals affirmed on 29 July 1994; and Bachrach's motion for reconsideration was denied on 15 May 1995, rendering the ejectment judgment final and executory on 20 May 1995.
While a motion for reconsideration was pending at the Court of Appeals, Bachrach filed on 28 March 1995 a separate complaint for specific performance in the Manila RTC, docketed Civil Case No. 95-73399, alleging a compromise agreement reached 4 February 1994 that superseded the ejectment proceedings and praying for specific performance. On 8 June 1995 PPA moved for writ of execution/garnishment in the ejectment case. On 9 June 1995 Bachrach sought a TRO/preliminary injunction in the specific performance case to enjoin issuance of the execution writ.
On 13 July 1995 the RTC issued an omnibus order granting preliminary injunction upon bond of P300,000, lifting/setting aside an order dated 5 June 1995 and denying PPA's motion for a preliminary hearing on affirmative defenses; the RTC denied reconsideration on 29 August 1995. PPA filed a certiorari/prohibition petition (CA-G.R. SP No. 38508) with the Court of Appeals on 25 September 1995, which the CA dismissed for insufficiency in form and substance on 28 September 1995. After receiving a copy of that resolution, PPA filed a new petition (CA-G.R. SP No. 38673) on 11 October 1995, arguing, inter alia, that the RTC had no business enjoining the execution of a final appellate judgment, that subject matter and causes overlapped (res judicata), and that Bachrach had engaged in forum shopping.
The Court of Appeals, in its 12 November 1996 decision, granted PPA's peti...(Pro-only)
Issues:
- Is Bachrach’s specific performance action (Civil Case No. 95-73399) barred by res judicata because of the final and executory judgment in the unlawful detainer case (Civil Case No. 138838)?
- Did the RTC exceed its jurisdiction or commit grave abuse by issuing a writ of preliminary injunction to enjoin the execution o...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)