G.R. No. 109656 - La Tondena Distillers, Inc. vs. Ponferrada

Several persons (herein referred to as defendants) entered into a contract to sell a parcel of land located in Bago City to private respondents.
The defendants later reneged on their contractual obligation, leading to a breach that prompted the private respondents to seek legal relief.

On August 25, 1987, private respondents filed an action for “specific performance with damages” before the Regional Trial Court (RTC) of Bacolod City.
A notice of lis pendens was annotated on the title of the land, highlighting the pending litigation.

The notice of lis pendens was canceled on November 9, 1988 when defendants filed a bond.
While the case was pending with a trial scheduled in November 1991, petitioner purchased the disputed lot from the defendants.

Private respondents, aggrieved by the petitioner’s acquisition of the property, amended their complaint.
The petitioner was impleaded as an additional defendant, with private respondents contesting that the petitioner was not a buyer in good faith.

No cause of action, contending that it was a buyer in good faith given that the notice of lis pendens had already been canceled.
Improper venue, arguing that the case should be heard in Bago City where the land is located rather than in Bacolod City.

The lower court issued a resolution on October 1, 1992 denying the motion, with a subsequent motion for reconsideration denied on January 20, 1993.

On April 21, 1993, petitioner directly elevated the issue to the Supreme Court via a petition for certiorari under Rule 65, challenging the RTC’s denial of its motions.
Following submission of memoranda by the parties, petitioner filed a “manifestation” alleging that, in September 1992, it sold the lot to Distileria Bago, Inc.—an entity with which it had substantial stockholdings.
Private respondents then moved to dismiss the petition on the basis that petitioner was no longer a real party in interest after having allegedly sold the property.

The key issue revolved around the proper remedy available when the lower court denies a motion to dismiss an interlocutory order.
The petitioner’s recourse should have been to file an answer and raise the objections within the trial proceedings rather than resorting to an extraordinary remedy.
The petition was additionally compromised by its filing beyond the reasonable period (more than three months after receipt of the RTC resolutions).

Whether the petition for certiorari was filed within the reasonable period considering it was submitted more than three months after the lower court’s denial of the motion to dismiss.
Whether the petitioner’s elevation of the case via certiorari was proper given the procedural timeframe and requirements.

Whether an interlocutory order—specifically, the RTC’s denial of the motion to dismiss—can be immediately contested through certiorari.
The appropriateness of invoking certiorari for an order that is not yet final or appealable.

Whether the petitioner, having acquired the land after the cancellation of the lis pendens, qualifies as a buyer in good faith.
Whether the subsequent sale of the property to another entity affects its standing in the litigation as a real party in interest.

Whether the RTC of Bacolod City was the proper venue, or if the action should have been filed in Bago City since the property is located there.
The implications of classifying the case as one for “specific performance with damages” and its effect on venue determination.