Case Digest (G.R. No. 171765) Core Legal Reasoning Model
Facts:
On April 29, 2003, the incorporators of Mindanao Institute Inc. (MI Incorporators), represented by Engineer Victorioso D. Udarbe, filed a Petition for Declaratory Relief with a Temporary Restraining Order (TRO) and Preliminary Injunction against the United Church of Christ in the Philippines (UCCP), represented by Reverend Rodolfo Baslot, before the Regional Trial Court (RTC) of Cabadbaran, Agusan del Norte. The MI Incorporators sought to have MI declared the sole owner of its properties and to prevent UCCP from taking over MI’s properties, which UCCP claimed rightful ownership based on certain documents. The RTC issued a TRO restraining UCCP from seizing control of MI’s assets. Meanwhile, MI amended its Articles of Incorporation (AOI), which UCCP contested in a separate complaint filed on June 11, 2003, alleging invalidity due to lack of majority vote and discriminatory by-laws provisions. The RTC granted a writ of preliminary injunction on July 4, 2003, restraining UCCP from t Case Digest (G.R. No. 171765) Expanded Legal Reasoning Model
Facts:
Background of the Case The case involves a dispute over the ownership and control of the properties of Mindanao Institute, Inc. (MI), a non-stock corporation. The petitioners are the incorporators of MI, represented by Engr. Victorioso D. Udarbe, while the respondent is the United Church of Christ in the Philippines (UCCP), represented by Rev. Rodolfo Baslot. The petitioners filed a Petition for Declaratory Relief with a prayer for a Temporary Restraining Order (TRO) and Preliminary Injunction before the Regional Trial Court (RTC) of Cabadbaran, Agusan del Norte, to prevent UCCP from taking over MI’s properties.Legal Proceedings
On June 5, 2003, UCCP filed an Answer with Counterclaim, asserting ownership of MI’s properties based on certain documents. On June 10, 2003, the RTC issued a TRO in favor of the petitioners, reasoning that MI would suffer irreparable damage if UCCP took control of its assets. UCCP later filed a Complaint for Declaration of Nullity of the 2003 Amended Articles of Incorporation and By-Laws of MI, arguing that the amendments were invalidly adopted without the required majority vote.
RTC’s Issuance of Preliminary Injunction
The RTC granted the petitioners’ prayer for a preliminary injunction on July 4, 2003, restraining UCCP from taking over MI’s properties. The court based its decision on the presumption of validity of the amended Articles of Incorporation, which were approved by the Securities and Exchange Commission (SEC). UCCP moved for reconsideration, but the motion was denied. Judge Doyon, the presiding judge, later inhibited himself from the case after his son’s law firm entered its appearance as collaborating counsel for UCCP.
CA’s Decision
UCCP and MI, represented by Dr. Edgardo R. Batitang, filed a petition for certiorari before the Court of Appeals (CA), which granted the petition on September 30, 2005. The CA dissolved the preliminary injunction, stating that the MI incorporators had not shown a clear legal right to the protection they sought. The CA also upheld Judge Doyon’s inhibition, citing Rule 3.12(d) of the Code of Judicial Conduct. The MI incorporators moved for reconsideration, but the motion was denied by the CA.
Issues:
- Whether the Court of Appeals erred in resolving factual issues not yet heard and tried in the trial court.
- Whether the Court of Appeals erred in applying Rule 3.12(d) of the Code of Judicial Conduct in disqualifying Judge Doyon.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)