G.R. No. 108871 - People vs. Ballabare

On September 23, 1994, Megaworld Properties and Holdings, Inc. (developer) and Majestic Finance and Investment Co., Inc. (owner) executed a JVA for the development of a 215-hectare residential subdivision in General Trias, Cavite.
Key provisions of the JVA and its September 24, 1994 addendum:

Developer to secure the property from squatters, advance relocation/resettlement costs, and deposit an initial P10 million (increased to P60 million) for tenant claims and government permits.
Owner to deliver documents, allow possession, pay real estate taxes, allocate resettlement sites, and later reimburse advances and transfer titles of subdivided lots.

On October 27, 1994, Megaworld assigned all rights and obligations to Empire East Land Holdings, Inc., and Andrew L. Tan joined the developer side.

On February 29, 2000, owner filed a complaint for specific performance with damages (Civil Case No. 67813) alleging developer’s failure to maintain round-the-clock security as required by Article III(j) of the JVA.
During pre-trial, parties negotiated an amicable settlement; presentation of evidence was suspended.
On September 16, 2002, owner filed a motion to compel interim security measures; developer opposed, invoking reciprocal-obligations principle and prematurity.
On November 5, 2002, the RTC ordered the developer to provide sufficient round-the-clock security; motion for reconsideration was denied on May 19, 2003.

On August 4, 2003, developer filed a certiorari petition in the CA, alleging grave abuse of discretion by the RTC in issuing the security order prematurely and disregarding reciprocal obligations.
On April 27, 2005, the CA dismissed the petition, ruling the security obligation was existing and demandable since execution of the JVA, and interim measure was justified.
On May 26, 2005, developer moved for reconsideration; denied by CA on September 12, 2005.
Developers elevated the case to the SC via petition for review on certiorari.

Whether the developer’s obligation to provide round-the-clock security became demandable notwithstanding the owner’s alleged failure to perform its reciprocal obligations under the JVA and addendum.

Whether the RTC gravely abused its discretion in directing interim security measures before trial on the merits and during amicable negotiations.

Whether the November 5, 2002 order constituted an unauthorized interlocutory remedy—neither a status quo ante order nor an injunctive relief under Rules 56–61—thus exceeding the RTC’s jurisdiction.