Title
Sanson vs. Barrios
Case
G.R. No. 45086
Decision Date
Jul 20, 1936
Petitioner sought mandamus to compel appointment of a receiver, alleging irreparable harm; SC dismissed, ruling mandamus improper to review judicial discretion absent clear legal right or gross abuse.
A

Case Digest (G.R. No. 173138)

Facts:

In a previous mandamus proceeding, the petitioner Serafin Sanson sought to compel the respondent judge of the Court of First Instance of Iloilo to rule on a petition for the appointment of a receiver in civil case No. 9208, involving disputes with Isabel Araneta and others. Following the directing order of this court, a hearing was held, and the respondent judge ultimately denied the petition on the ground that the evidence did not establish the necessity to appoint a receiver. The petitioner then filed a new application for a writ of mandamus, arguing that the immediate appointment of a receiver was imperative—given the full swing of the harvest season—to protect his interests against irreparable damage. He contended that, although the respondent judge possessed discretion regarding the appointment, his refusal constituted a gross abuse of that discretion and that no other plain, speedy, and adequate remedy was available.

Issues:

  • Whether the petitioner’s right to the appointment of a receiver was clearly established such that the respondent judge’s duty to act was both clear and peremptory.
  • Whether mandamus is the proper remedy to compel a judge to exercise his discretion in appointing a receiver in a pending civil case.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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