Case Digest (G.R. No. 190112) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 2008, members Primo Co, Sr., Edgardo Cruz, Fe Lanny L. Alegado, Jester B. Ongchuan, Joseph Ongchuan and Lucianne Cham (collectively, the petitioners) of Philippine Canine Club, Inc. (PCCI) registered their dogs with the newly formed Asian Kennel Club Union of the Philippines, Inc. (AKCUPI). Without consulting its non-voting members, PCCI’s Board of Directors amended its By-laws on May 17, 2008 to include Article VI, Section 6.2(d) penalizing “participation in … an organization … prejudicial to the best interest of PCCI.” The Securities and Exchange Commission approved these amendments on August 22, 2008. Thereafter, PCCI’s Board suspended and expelled Co, Cruz, Alegado and Jester for purportedly violating the new provision, stripped Co’s champion dog of its title, barred Cruz from judging shows, and threatened Joseph and Cham with the same sanctions. On January 7, 2009, the petitioners filed Civil Case No. Q-09-207 for annulment of the Amended By-laws, injunction and damages Case Digest (G.R. No. 190112) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- The Philippine Canine Club, Inc. (PCCI) is a non-stock, non-profit entity promoting purebred dogs; petitioners (Co, Cruz, Alegado, J. Ongchuan, Jester, Cham) are non-voting members.
- In 2008, the Asian Kennel Club Union of the Philippines, Inc. (AKCUPI) was formed; petitioners registered their dogs with AKCUPI.
- Amended By-Laws and SEC Approval
- On May 17, 2008, PCCI amended Article VI (Suspension, Expulsion, Termination) to bar members from affiliating with “prejudicial” organizations.
- The Securities and Exchange Commission approved the Amended By-Laws on August 22, 2008.
- PCCI’s Disciplinary Actions
- PCCI’s Board suspended Co, Cruz, Alegado, and Jester and sent expulsion notices dated December 15, 2008.
- Joseph Ongchuan and Lucianne Cham were threatened with the same sanctions but not formally suspended or expelled.
- RTC Proceedings and Injunctive Relief
- On January 7, 2009, petitioners filed for annulment of the Amended By-Laws, damages, and injunctive relief; RTC Branch 93 granted a TRO on January 14, 2009.
- On February 4, 2009, RTC issued a Writ of Preliminary Injunction restraining PCCI from enforcing the Amended By-Laws against all petitioners, upon P200,000 bond.
- CA Proceedings
- PCCI filed a petition for certiorari with the Court of Appeals (CA), which on June 15, 2009, reversed the RTC, ruling injunctive relief was tainted by grave abuse of discretion.
- The CA held that, being consummated, the enforcement of the Amended By-Laws and penalties could no longer be enjoined; its denial of reconsideration was dated October 29, 2009.
Issues:
- Whether a writ of preliminary injunction may enjoin enforcement of the PCCI Amended By-Laws and expulsion/suspension already implemented.
- Whether Dayrit v. Delos Santos, allowing injunction of continuing acts, applies when some acts (suspension/expulsion) are completed and others are only threatened.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)