Case Digest (G.R. No. 180988)
Facts:
Respondent Richard Emmanuel G. Dancel entered into franchise agreements with petitioner Julie’s Franchise Corporation covering three bakeshop outlets in Dipolog City and Zamboanga del Norte, later renewing the franchises for five years with renewal fees paid by 2004. After dissolution of Dancel’s partnership, petitioner informed Dancel that it would terminate the franchises and that the extended term would expire on 30 June 2005. Dancel filed Civil Case No. 6108 in the Regional Trial Court, Branch 10, Dipolog City, seeking specific performance with a prayer for a writ of preliminary injunction or temporary restraining order; the trial court initially denied the application for lack of jurisdiction.
On appeal, the Court of Appeals in CA-G.R. SP No. 00740 ordered the trial court to issue the writ with dispatch, and the petitioners’ subsequent attempts to elevate the matter failed due to lateness. Acting on the final and executory appellate decision, the trial court issued a Writ of Preliminary Mandatory and Prohibitory Injunction on 23 July 2007; petitioners’ motions for reconsideration and for dissolution or lifting were denied on 8 October 2007 and 16 November 2007, respectively. Petitioners then filed a petition for certiorari on 28 December 2007, including matters relating to an indirect contempt case pending in another branch, Regional Trial Court, Branch 9, Dipolog City.
Issues:
- Whether Judge Ruiz acted without jurisdiction in issuing the writ of preliminary injunction to enjoin acts committed or about to be committed outside the trial court’s territorial boundaries.
- Whether Judge Ruiz committed grave abuse of discretion by extending the expired franchise contracts through the issuance of the preliminary injunction.
- Whether Judge Ruiz gravely abused discretion in granting the preliminary injunction despite alleged prejudgment of the case.
- Whether Judge Ruiz gravely abused discretion in not voluntarily inhibiting due to alleged prejudgment.
- Whether Judge Ruiz gravely abused discretion in not dismissing the case on summary judgment based on alleged judicial admissions and lack of cause of action.
- Whether Judge Ruiz gravely abused discretion in granting the preliminary injunction despite alleged absence of a right in esse.
- Whether Judge Ruiz gravely abused discretion by not granting a preliminary injunction in favor of JFC to protect its intellectual property rights.
- Whether the indirect contempt charge may be enjoined in this certiorari proceeding.
- Whether petitioners were entitled to a restraining order and/or writ of preliminary injunction to enjoin the two Dipolog City courts from enforcing the assailed writ during the pendency of the petition.
Ruling:
The petition was dismissed for lack of merit. The Court held that there was no grave abuse of discretion in issuing the writ because the trial court merely followed the Court of Appeals decision in CA-G.R. SP No. 00740, which had become final and executory.
The Court further held that issues involving errors of judgment—such as denial of summary judgment, the assessment of cause of action, and the alleged failure to grant an injunction for intellectual property—were not reviewable via certiorari. It also declined to resolve the challenge to the separate indirect contempt case in Branch 9, as it should have been brought in a separate appropriate action.
Ratio:
The Court emphasized that certiorari under Rule 65 corrects errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction. It ruled that the propriety of the writ of preliminary injunction had already been resolved by the Court of Appeals and could no longer be revisited, since the Supreme Court denied petitioner’s late-filed petition and final judgments are binding and generally immutable except for clerical errors.
On the remaining issues, the Court characterized petitioners’ claims as attacks on the trial court’s exercise of judgment rather than jurisdictional infirmities. The Court also found that the indirect contempt matter pertained to a different case before another branch and therefore did not properly belong in the certiorari petition, which was accordingly dismissed.
Doctrine:
- Rule 65 certiorari lies only to correct errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction.
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