G.R. No. 88373 - Enrile vs. Capulong

Juan Ponce Enrile, acting as petitioner, commenced a suit in the Regional Trial Court (RTC) of Makati, Civil Case No. 88-151, seeking to enjoin the production of the mini-series film “The Four Day Revolution.”
The complaint alleged that the production—initiated without Enrile’s consent and over his objection—violated his constitutional right to privacy and constituted an unlawful intrusion into his private life.
The complaint also contained a prayer for damages, although the central relief pursued was an injunction.

On February 24, 1988, the RTC issued an ex parte Temporary Restraining Order (TRO) against the petitioners, pending a hearing on the application for a writ of preliminary injunction.
On March 9, 1988, Hal McElroy filed a Motion to Dismiss the petition for a preliminary injunction, arguing that the mini-series did not invade Enrile’s private life and that a preliminary injunction would amount to a prior restraint on free expression.
Simultaneously, Ayer Productions filed its own Motion to Dismiss, contending that the mini-series had not been completed and the cause of action was lacking.

On March 16, 1988, the RTC issued a writ of Preliminary Injunction ordering the petitioners, their employees, and persons acting on their behalf to cease production of the mini-series, refrain from mentioning Enrile or his family, and avoid creating any fictitious characters identifiable with him.
The writ required that no further production take place without the petitioner’s posting of a bond amounting to P2,000,000.00 to cover potential damages.

Petitioner Ayer Productions filed a Petition for Certiorari with an urgent prayer for a Preliminary Injunction/Restraining Order on March 21, 1988, followed a day later on March 22, 1988, by Hal McElroy’s separate petition.
The Supreme Court consolidated these petitions and required the private respondent (Enrile) to file a consolidated answer, in which he predominantly invoked his right to privacy.
On April 29, 1988, the Supreme Court rendered its Decision where it:

Set aside the RTC’s writ of Preliminary Injunction issued on March 16, 1988.
Modified and made permanent the TRO issued on March 24, 1988, thereby enjoining the implementation of the RTC’s earlier order.
Directed that Judge Teofilo Guadiz of RTC Makati, Branch 147, dismiss Civil Case No. 88-413 in connection with the matter.

A Motion for Reconsideration was filed on May 16, 1988 by the petitioner and was ultimately denied on June 9, 1988.
The Supreme Court’s Decision was entered on June 20, 1988, marking finality of judgment in that respect.
Subsequent to the entry of judgment:

The private respondent (Ayer Productions, by its subsequent actions and claims) alleged that the wrongly issued injunction caused significant logistical and financial damages.
In response to these alleged damages, the private respondent filed various motions for depositions, claims for damages, and procedural motions, including a “Motion to Resolve” on November 24, 1988, and additional motions in early 1989 regarding deposition suppression and claim for damages.

On January 19, 1989, the RTC rendered an Order dismissing the main case.
Further RTC orders on May 2, 1989, and June 1, 1989, allowed the private respondent’s application for damages and the taking of depositions, thereby reigniting the damages discussion despite the earlier Supreme Court ruling.

Petition for Certiorari and Prohibition to Interrupt Lower Court Proceedings

On June 6, 1989, petitioners filed the present Petition for Certiorari and Prohibition, seeking to stop the RTC from proceeding further with the damages application and related discovery.
The petitioner contended that these lower court orders unlawfully allowed proceedings on a damages claim despite the Supreme Court’s earlier, definitive ruling that Enrile had no cause of action for injunction (and, by extension, for damages).

The RTC acted with grave abuse of discretion in admitting the claim for damages, which should have been extinguished by the Supreme Court’s Decision.
The filing of the claim for damages was untimely as it occurred after the finality of the Supreme Court’s Decision (entered on June 20, 1988) or, alternatively, should be measured from the RTC’s dismissal order of January 19, 1989, a point contested by both sides.
The lower court improperly allowed depositions and discovery in connection with the damages claim, thereby reviving a matter that had already been settled on its merits.

Whether the claim for damages arising from the wrongful preliminary injunction was filed before the judgment on the merits became final.
Whether finality should be reckoned from the Supreme Court’s Decision (and its entry on June 20, 1988) or from the RTC’s dismissal order issued on January 19, 1989.

Whether the RTC acted without or in excess of jurisdiction by admitting the private respondent’s application for damages despite the Supreme Court’s prior ruling dismissing Enrile’s cause of action for injunctive relief.
Whether the RTC’s decision to allow depositions and further discovery in connection with the damages claim was proper under the established rules of procedure.

Whether the surety bond filed by the petitioner (in the amount of P2,000,000.00) should indemnify the respondents in light of the Supreme Court’s determination that Enrile had no right to obtain relief.
The implications of allowing a claim for damages against the bond when the underlying cause of action had been extinguished by prior judicial pronouncement.

Whether the proceedings in the lower court regarding the damages claim should have been merged with the main case, or disposed of separately, given that the Supreme Court’s ruling on the merits had rendered further proceedings unnecessary.