Case Digest (G.R. No. 86051) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 2007, Edgar T. Barroso filed a complaint for sums of money, damages, and attorney’s fees with the Regional Trial Court of Davao City, Branch 16, against Dennis Li, including a prayer for a writ of attachment. After Li’s answer, RTC-Br. 16 granted the attachment and approved Barroso’s bond, while Li posted a counter-attachment bond purportedly issued by Travellers Insurance & Surety Corporation. On January 22, 2008, RTC-Br. 16 approved a compromise agreement, but Li defaulted on payment. Barroso then secured a writ of execution solely against Li, which proved unsatisfied. On April 2, 2009, RTC-Br. 16 ordered an alias writ of execution against both Li and Travellers, based on the counterbond. Travellers sought validation of its bond but instead filed on July 10, 2009, an independent petition for Declaration of Nullity, Prohibition, Injunction, and Damages with Prayer for TRO and Preliminary Injunction in RTC-Br. 14, seeking to nullify the counterbond, enjoin enforcement of the Case Digest (G.R. No. 86051) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Proceedings in RTC-Br. 16, Davao City
- In 2007, Edgar T. Barroso (petitioner) filed a complaint for sum of money, damages, and attorney’s fees against Dennis Li, including a prayer for a writ of attachment.
- RTC-Br. 16 granted the writ of attachment; Dennis Li posted a counter-attachment bond purportedly issued by Travellers Insurance & Surety Corporation (Travellers).
- On January 7, 2008, petitioner moved to approve a compromise agreement; on January 22, 2008, RTC-Br. 16 rendered a judgment on compromise.
- Dennis Li failed to comply with the compromise; petitioner filed for execution. A writ of execution against Li was returned unsatisfied.
- Execution upon counter-bond and separate action in RTC-Br. 14
- Petitioner moved for execution against the counter-bond; RTC-Br. 16 issued an order on April 2, 2009, held a summary hearing, and issued an alias writ of execution on April 28, 2009, against both Li and Travellers.
- Travellers requested seven days to validate the counter-bond (July 1, 2009), but instead filed on July 10, 2009, a petition for declaration of nullity, prohibition, injunction, and damages in RTC-Br. 14, praying for:
- TRO and preliminary injunction enjoining enforcement of the April 28 writ of execution;
- declaration nullifying the counter-bond;
- actual and moral damages, attorney’s fees, and costs.
- On July 29, 2009, RTC-Br. 14 issued a writ of preliminary injunction. The judge ruled that his court was the “proper forum” to determine the authenticity of the counter-bond and that an exception to non-interference with a coordinate court allowed issuance of the injunction.
- Petition for certiorari in the Supreme Court
- Petitioner’s motion for reconsideration was denied on September 15, 2010.
- Petitioner filed a Rule 65 certiorari petition in the Supreme Court, alleging:
- RTC-Br. 14 acted without jurisdiction;
- preliminary injunction issued without requiring an injunction bond;
- improper exercise of jurisdiction over an executive sheriff of a co-equal court.
- Travellers contended that RTC-Br. 14 had jurisdiction to resolve the validity of the contract (counter-bond) and questioned the bond’s authenticity.
Issues:
- Did RTC-Br. 14 have jurisdiction to issue a preliminary injunction against the writ of execution issued by RTC-Br. 16?
- Was the writ of preliminary injunction null and void for violating the rule on non-interference among coordinate courts?
- Should the court have required Travellers to post an injunction bond before issuing the preliminary injunction?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)