G.R. No. 193138 - Saludo, Jr. vs. Philippine National Bank

On June 11, 1998, Saludo Agpalo Fernandez & Aquino Law Office (SAFA Law Office), a partnership for the practice of law, entered into a Contract of Lease with Philippine National Bank (PNB) for 632 sqm on the 2nd floor of PNB Financial Center, Quezon City, at P189,600.00 per month, with a 10% annual escalation, three-year term.
SAFA Law Office paid advance rentals and security deposit totaling P1,137,600.00.

After lease expiration on August 1, 2001, SAFA Law Office remained in possession until February 2005, ceasing rent payments after December 2002.
PNB sent successive demand letters in July and November 2003, and July 2005, claiming unpaid rents escalating from P4,648,086.34 to P10,951,948.32, later P25,587,838.09.
SAFA Law Office proposed to negotiate, alleging inducements by former PNB management—special rates, case referrals, external counsel engagements—and sought discounts and credits for improvements and professional fees. PNB declined and insisted on full payment.

September 1, 2006: Petitioner Aniceto G. Saludo, Jr., as managing partner, filed an amended complaint against PNB for accounting and recomputation of unpaid rentals and damages.
October 4, 2006: PNB moved to include SAFA Law Office as indispensable co-plaintiff; October 13, 2006: PNB filed its answer with compulsory counterclaims for P25,587,838.09 against Saludo and SAFA Law Office.
October 23, 2006: Saludo moved to dismiss counterclaims, asserting SAFA Law Office is a non-legal entity/single proprietorship and cannot be sued.
January 11, 2007: RTC Branch 58 Makati issued an Omnibus Order denying joinder of SAFA Law Office and granting Saludo’s motion to dismiss counterclaims as SAFA “non-legal entity.”
March 8, 2007: RTC denied PNB’s motion for reconsideration. PNB elevated to Court of Appeals (CA) via certiorari.
February 8, 2010: CA partly granted petition, reinstating PNB’s counterclaims against Saludo and SAFA Law Office but affirmed denial of joinder of SAFA as plaintiff, holding SAFA a non-legal entity yet could be sued under Section 15, Rule 3 of the Rules of Court.
August 2, 2010: CA denied both parties’ motions for reconsideration, further ruling SAFA Law Office must be joined as defendant to counterclaim for “complete relief.”
Saludo petitioned the Supreme Court raising three main issues on SAFA’s legal personality, CA’s scope, and CA’s interlocutory certiorari jurisdiction.

Whether the CA erred in including SAFA Law Office as defendant to PNB’s counterclaim despite holding it neither an indispensable party nor a legal entity.
Whether the CA exceeded the issues raised in the petition for certiorari by addressing the merits of PNB’s counterclaim.
Whether the CA erred in entertaining PNB’s certiorari petition to annul the RTC’s Omnibus Order dated January 11, 2007.