Case Digest (G.R. No. 204452)
Facts:
Metro Rail Transit Development Corporation v. Trackworks Rail Transit Advertising, Vending and Promotions, Inc., G.R. No. 204452, June 28, 2021, Supreme Court Third Division, Hernando, J., writing for the Court.
The dispute arose from a series of contracts and renewals between the Department of Transportation and Communication (DOTC), Metro Rail Transit Corporation (MRT), and Metro Rail Transit Development Corporation (MRTDC) concerning development and advertising rights over Phase 1 of the MRT-3 along EDSA, and a 1998 Contract for Advertising Services and a 2005 renewal between MRTDC and Trackworks Rail Transit Advertising, Vending and Promotions, Inc. (Trackworks) under which Trackworks agreed to operate and pay guaranteed minimums and revenue shares. Trackworks later defaulted in payments; MRTDC demanded payment and, after defaults persisted, issued a Notice of Termination on September 1, 2009.
Trackworks then filed Civil Case No. 77291-PSG in the RTC of Pasig City on November 23, 2009 seeking injunctive relief to prevent termination and to compel arbitration; the Pasig RTC on January 4, 2010 denied the injunctive relief but ordered the parties to submit to arbitration and stayed proceedings pending the arbitral award. Trackworks filed further motions in Pasig (denied on March 15 and May 28, 2010) and initiated arbitration with the Philippine Dispute Resolution Center, Inc. (PDRCI) on March 8, 2010.
Dissatisfied, Trackworks filed a Petition for Certiorari, Prohibition and Mandamus under Rule 65 before the RTC of Makati (Civil Case No. 10-414) on April 28, 2010, seeking injunctive relief restraining MRTDC, Media Puzzle Inc. (MPI), and DOTC officials from acts related to termination and permits. The Makati RTC initially granted a temporary restraining order and, after interlocutory proceedings, Branch 65 issued an Omnibus Order (October 22, 2010) denying MRTDC’s Motion to Dismiss and later a December 20, 2010 Order denying MRTDC’s motion for reconsideration; eventually Branch 65 promulgated a Decision on June 14, 2012 granting Trackworks’ petition and affording reliefs including injunctive and mandamus relief.
MRTDC filed a petition for certiorari before the Court of Appeals (CA) challenging Makati RTC’s October 22 and December 20, 2010 orders. On July 30, 2012 the CA granted MRTDC’s petition, annulled the Makati RTC orders, and dismissed Civil Case No. 10-414. Upon Trackworks’ motion for reconsideration, however, the CA reversed itself on November 9, 2012, holding that the Makati RTC’s June 14, 2012 Decision rendered MRTDC’s certiorari petition moot because an ordinary appeal had become available; the CA dismissed MRTDC’s petition for certiorari on that ground.
(Subscriber-Only)
Issues:
- Has the Petition for Certiorari filed by MRTDC before the Court of Appeals been rendered moot by the June 14, 2012 Decision of the RTC of Makati City, Br...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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