Case Digest (G.R. No. 159108)
Facts:
Gold Line Tours, Inc. (Petitioner) claimed ownership of a tourist bus levied to satisfy a final June 30, 1997 RTC judgment in Civil Case No. 93-5917 in favor of the Heirs of Maria Concepcion Lacsa (Respondents) for the death of Concepcion Lacsa in an August 2, 1993 collision involving a Goldline bus operated by Travel & Tours Advisers, Inc.. The RTC denied petitioner's verified third-party claim on August 2, 2001 and denied reconsideration on October 22, 2001; the Court of Appeals affirmed on October 30, 2002, and the petition for certiorari to the Supreme Court followed.
Issues:
- Did the RTC commit grave abuse of discretion in denying petitioner's verified third-party claim?
- Was the levy of the bus valid despite petitioner not having been impleaded in Civil Case No. 93-5917?
Ruling:
The Court denied the petition for review on certiorari and affirmed the Court of Appeals' decision. The Court held that the RTC did not gravely abuse its discretion in dismissing the third-party claim and that the levy of the bus was proper.
Ratio:
The RTC and the Court of Appeals had sufficient factual basis to find that Gold Line Tours, Inc. and Travel & Tours Advisers, Inc. were one and the same, citing common management and use of the Goldline trade name and incorporators’ identities; therefore the corporate veil could be pierced to prevent use of corporate fiction to defeat execution. The petitioner, seeking relief by certiorari, failed to show grave abuse of discretion amounting to lack or excess of jurisdiction, and factual findings on identity and liability are not reviewable by certiorari.
Doctrine:
- The fiction of separate corporate personality may be disregarded to prevent fraud or to defeat the ends of justice.
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