G.R. No. 13952 - Ahern vs. Julian

On August 10, 1998, Multi-Luck Corporation (Multi-Luck) filed a collection suit against Alberto T. Looyuko, the sole proprietor of Noah’s Ark Merchandising Inc. (NAMI), alleging dishonor of three UCPB checks amounting to P8,985,440.00.
The checks, originally issued by Looyuko/NAMI to Mamertha General Merchandising and subsequently indorsed to Multi-Luck as a holder in due course, formed the basis of the collection action.
On January 27, 2000, upon Multi-Luck’s motion for judgment on the pleadings, the Bacolod RTC ruled in favor of Multi-Luck, ordering Looyuko/NAMI to pay the amount specified. No appeal was filed, rendering the decision final and executory.
Following the decision, the Bacolod RTC issued a writ of execution, targeting a house and lot (TCT No. T-126519) registered in Looyuko’s name and one share in the Negros Occidental Golf and Country Club, Inc. (registered in the name of NAMI). Auction sales were scheduled for November 10 and November 6, 2000, respectively.

On October 25, 2000, petitioner Jimmy T. Go filed a complaint for injunction before the RTC of Pasig City, Branch 266 (Civil Case No. 68125), seeking a temporary restraining order and/or writ of preliminary injunction.
In his complaint, petitioner claimed to be a “business partner” of Looyuko and alleged co-ownership of the properties subject to auction, arguing that his share would be unfairly disposed of without due process once the execution took place.
Respondents, which included the Clerk of Court, ex-officio Provincial Sheriff of Negros Occidental, and others, along with Multi-Luck, opposed the petition. Multi-Luck, among other arguments, contended that the Pasig RTC lacked jurisdiction over the matter.

On October 30, 2000, the Pasig RTC granted petitioner’s prayer by issuing a Temporary Restraining Order (TRO).
On November 23, 2000, the Pasig RTC further issued a writ of preliminary injunction to bar the public respondent sheriffs from conducting the scheduled auction sale.
On December 7, 2000, the Pasig RTC denied respondents’ motion to dismiss the petition.
Multi-Luck later filed motions for reconsideration of these orders; however, they were denied in separate orders dated February 2, 2001.

Multi-Luck elevated the case to the Court of Appeals (CA) via a petition for certiorari and prohibition, seeking to reverse the provisional orders of the Pasig RTC.
On April 30, 2002, the CA reversed the Pasig RTC’s orders, holding that the issuance of the writ of preliminary injunction by a co-equal court interfered with the Bacolod RTC’s final and executory decision in Civil Case No. 98-10404.
The CA found that the petitioner lacked a clear legal right to justify the relief, emphasizing that a court with concurrent jurisdiction cannot interfere with the actions of another that is already vested with the authority over the matter.
Petitioner’s subsequent motion for reconsideration in the CA was denied on July 31, 2002.

Petitioner asserted that he held an interest in the properties through a partnership relationship evidenced by the Agreement dated February 9, 1982, and a subsequent Agreement dated October 10, 1986.
The agreements purported to show an equal sharing of profits, losses, and other assets between the parties.
Despite these assertions, the authenticity and execution of the agreements were under separate litigation, and the longstanding practice of operating NAMI as a registered single proprietorship cast doubts on petitioner’s claim of co-ownership.
Petitioner further argued that as a “third party claimant” under Rule 39, Section 16 of the Rules of Court, he should not be bound by the judgment in Civil Case No. 98-10404.

Whether a lower court (Pasig RTC) had the power to issue a writ of preliminary injunction that interfered with the execution of the final decision rendered by the Bacolod RTC.
Whether any court of concurrent jurisdiction may interfere with the judgments or orders of another when execution proceedings are pending.

Whether petitioner, appearing as a “third party claimant” and alleging co-ownership through partnership agreements, established a clear, positive, and legally protectable right (right in esse) justifying injunctive relief.
Whether the mere claim of interest, without impleading in the original collection suit (Civil Case No. 98-10404), may suffice for obtaining a preliminary injunction.

Whether the doctrine that prevents one court from interfering with another’s judgments applies in this case, thereby barring the Pasig RTC from issuing an injunction against proceedings conducted by the Bacolod RTC.
Whether the exception cited in Santos v. Bayhon is applicable to the circumstances presented by petitioner.

Whether the existence (or alleged existence) of partnership agreements between petitioner and Looyuko could confer upon petitioner an equitable and substantive right to the properties subject to the execution order.
Whether the registration status of Noah’s Ark Merchandising as a single proprietorship overrides the equitable claims based on the agreements.