G.R. No. 213241 - Philippine National Bank vs. Vila

La Tondena Distillers, Inc. (plaintiff) initiated an action for “replevin with damages” in the Regional Trial Court (RTC) of Manila, Branch 38, alleging wrongful possession of its specially manufactured, registered white flint bottles used for its gin, popularly known as “Ginebra San Miguel.”
These bottles, which bear the marks “LA TONDENA, INC.” and “GINEBRA SAN MIGUEL,” were duly registered with the Philippine Patent Office pursuant to Republic Act No. 623 (as amended by RA 5700).

Plaintiff alleged that the sale of its gin did not include the transfer of the bottles, a fact underscored by its sales invoices.
It claimed that a person identified in the complaint as “Te Tien Ho”—a junk dealer operating a second-hand store at 1005 Estrada St., Singalong, Manila—was in wrongful possession of approximately 20,250 regulated bottles valued at P20,000.00.
Citing Section 2 of RA 623 (as amended), the plaintiff contended that any use or sale of the registered bottles without its written consent is unlawful.

Upon filing a verified complaint and posting a bond of P40,000.00, Judge Natividad G. Adduru-Santillan issued a writ of delivery on February 13, 1989.
Deputy Sheriff Regio Ruefa subsequently seized 20,250 bottles from the premises at 1105 Estrada St., Singalong, Manila, and executed a receipt detailing the seizure.
Notably, the receipt described the defendant as “Te Tien Ho,” though evidence later indicated that the person in possession was also known as “Tee Chin Ho,” the owner of a junk shop.

An individual identifying himself as “Tee Chin Ho” filed a pleading on March 1, 1989, seeking to intervene as a party with a preliminary injunction and compulsory counterclaim.
His answer asserted that (a) ownership of the bottles was transferred upon purchase (since the sale did not include the bottles as part of the gin), (b) the actual seizure occurred at his establishment at 1105 Estrada St. rather than the address stated in the complaint, and (c) the seizures were part of a series of maneuvers allegedly masterminded by La Tondena.
A receipt from an earlier seizure (October 6, 1988) by Manila Police further complicated the record by introducing an additional quantity (432 boxes/50, or 21,600 bottles) allegedly taken, which Tee Chin Ho later sought to have returned.

On April 7, 1989, Judge Adduru-Santillan ruled in favor of the intervenor (Tee Chin Ho) by:

Granting his motion to intervene as a party defendant.
Issuing a writ of preliminary mandatory and prohibitory injunction directing La Tondena to restore all 41,850 bottles (including those seized earlier by the Manila Police and the subsequent seizure by the sheriff) to Tee Chin Ho.

La Tondena moved to amend its complaint to correct the mistaken designation (“Te Tien Ho” instead of “Tee Chin Ho”) and to dismiss the intervention motion, alleging that the error was harmless and had been waived by the intervenor.
Despite the motion to amend being one permitted as a matter of right under Rule 10 of the Rules of Court, the trial court deferred its resolution and concurrently processed the intervention.

Dissatisfied with the rulings, particularly the grant of the preliminary injunction and the manner of intervention, La Tondena assailed the trial court’s Order in the Court of Appeals.
The Court of Appeals, while granting a temporary restraining order to preserve the status quo, eventually dismissed La Tondena’s petition for certiorari, declaring that the errors did not warrant a reversal by that forum.
La Tondena then elevated the case to the Supreme Court on certiorari, alleging grave abuse of discretion, misapplication of RA 623 (as amended), procedural irregularities regarding intervention and amendment of pleadings, and misidentification of the defendant.

Whether the trial court erred in failing to determine correctly if “Tee Chin Ho” (the intervenor) was in fact the same person as “Te Tien Ho” named in the original complaint, thereby affecting his standing and the remedies available to him.
Whether the mistaken designation had legal consequences and prejudiced either party’s rights.

Whether permitting the intervenor, who was already served as a defendant, to file an answer-in-intervention and subsequent counterclaim circumvented the mandatory procedures—specifically the five-day period for objecting to the replevin bond’s sufficiency or posting a counter-bond.
Whether the trial court’s failure to immediately grant the plaintiff’s motion to amend the complaint (to correct identification errors) violated the rules of pleading and prejudiced the proper resolution of the dispute.

Whether the issuance of the writ of mandatory and prohibitory injunction, which ordered the return of not only the bottles seized pursuant to the replevin order but also those previously seized by Manila Police, was legally justified under RA 623 and the Rules of Court.
Whether the provisional remedy effectively resolved the merits of the controversy prematurely, thereby denying the plaintiff its right to litigate the substantive issue of bottle ownership.

Whether the trial court improperly allowed Tee Chin Ho to avail of remedies reserved for strangers (via intervention) despite being served as a defendant.
Whether the alternative remedies provided under Section 5 and Section 6 of Rule 60 were bypassed or misapplied in granting the injunction.