G.R. No. 172222 - Africa vs. Sandiganbayan

In 1955, the Court of First Instance of Rizal rendered judgments in ejectment cases Q-1401 and Q-1402 involving the eviction of occupants.
These judgments were later affirmed in toto by the Court of Appeals in cases CA-G.R. Nos. 16265-66-R ("Tuason & Company, Inc. vs. Bruna Rosete and Buenaventura Dizon").
On the finality of the appellate decision, the Quezon City branch of the Court of First Instance issued writs of execution against the evictees, leading to orders for the demolition of their houses on November 19, 1960.

Prior to the demolition orders, on November 16, 1960, J.M. Tuason & Company, Inc. applied for a writ of prohibition (Case No. Q-5527) against the Land Tenure Administration, the Auditor General, and the Solicitor General.
The petition was intended to restrain the initiation of expropriation proceedings over the “Tatalon Estate,” which were authorized by Republic Act No. 2616 enacted on August 3, 1959.
The company contended that RA No. 2616 was unconstitutional, claiming that it effectively deprived the company of its property rights for the benefit of squatters and other occupants even when the property had been subdivided and its lots sold.
Responding to the petition, Judge Hermogenes Caluag of the Quezon City Court of First Instance issued an ex parte writ of preliminary injunction on November 18, 1960—after the company’s filing of a bond of ₱20,000—to preserve the company’s rights pending the resolution of the prohibition case.

The evictees (Bruna Rosete and Tranquilino Dizon), who were tenants of the Tatalon Estate, moved for the suspension of the demolition orders by filing a petition to the Court of First Instance.
Judge Nicasio Yatco of the same court denied the motion to suspend demolition orders on the ground that no expropriation proceedings had yet been filed.
Consequently, the evictees resorted to filing certiorari proceedings (CA-G.R. No. 28842-R) before the Court of Appeals on February 4, 1961, challenging the actions of both Judge Caluag and Judge Yatco, and seeking relief in the form of injunctions against the demolition orders and the preliminary injunction.
The Court of Appeals, on February 9, 1961, issued a writ of preliminary injunction on an ex parte basis—with a ₱1,000 bond filing—intending to dissolve the preliminary injunction issued by Judge Caluag so that the Land Tenure Administration could proceed with the expropriation complaint.
Tuason & Company, Inc. contested the jurisdiction of the Court of Appeals, arguing that:

Its jurisdiction to grant writs such as injunction and prohibition is limited to cases where there is an appealable judgment on the merits.
The orders for execution and the prohibition proceeding, involving a constitutional question on RA No. 2616, are not within the appellate jurisdiction of the Court of Appeals.

In response to the Court of Appeals’ actions, Tuason & Company, Inc. instituted certiorari proceedings before the Supreme Court (G.R. No. L-18128) to set aside the CA’s writ of preliminary injunction.
Later, the Land Tenure Administration, dissatisfied with the interference, filed its own certiorari proceeding (G.R. No. L-18672) before the Supreme Court against Judge Caluag and Tuason & Company, Inc.
The petitioner Land Tenure Administration argued that Judge Caluag had abused his discretion by:

Issuing the preliminary injunction in the prohibition case.
Denying motions to dismiss the prohibition case.
Refusing to have the expropriation complaint docketed despite the Court of Appeals’ resolution quashing the previous injunction.

The underlying disputes essentially revolved around whether the Court of Appeals had jurisdiction to issue its injunction and whether Judge Caluag exceeded his jurisdiction in issuing the preliminary injunction in the prohibition case.

Whether the Court of Appeals had the jurisdiction to lift, quash, or dissolve the preliminary injunction issued by Judge Caluag in the prohibition case (Case No. Q-5527) pending before the Court of First Instance.
Whether such jurisdiction extends to matters that do not involve an appealable decision on the merits, specifically after ejectment judgments had become final and non-appealable.

Whether Judge Caluag acted without or in excess of his jurisdiction in issuing the preliminary injunction in the prohibition case.
Whether the issuance of the preliminary injunction was proper under the rules concerning writs and auxiliary processes, given that it was meant to preserve the rights of the parties during the pendency of the prohibition case.