G.R. No. 155374 - Santos vs. Court of Appeals

Case Digest (G.R. No. 155374)
Expanded Legal Reasoning Model

Facts:

Background and Parties

Respondents, Emmanuel B. Juan and Carmelita Juan Delos Santos, are the registered owners of a parcel of land in Barangay Ugong, Valenzuela City.
Petitioner, Dr. Antonio C. Santos, was permitted by the respondents to use an existing passage over the land for access, as were other adjoining property owners.
Rolando Lim, Officer In Charge of the City Engineering’s Office, is involved as a subject of the respondents’ allegations in connection with the events.

Developments Leading to the Dispute

In March 1999, the respondents decided to develop commercial buildings on the property.

They fenced the land and subsequently closed the pre-existing passage that allowed access to Barangay Que Grande Street.
Respondents opened an alternate passage on another side of their property, which also led to the same barangay road.

In May 1999, petitioner, with assistance from armed men, demolished the concrete fence that was blocking the old passage.

Respondents alleged that this demolition was executed without any court order and criticized the involvement of Lim in supporting the demolition.

Trial Court Proceedings

On 24 May 1999, Judge Floro P. Alejo of the Regional Trial Court (Branch 172, Valenzuela City) ordered a hearing for the issuance of a temporary restraining order (TRO) in connection with the respondents’ complaint.
On 27 May 1999, during the hearing:

Both parties were directed to submit their respective position papers within five (5) days, complete with affidavits and documentary evidence, for the incident concerning the TRO.

On 9 June 1999, the trial court issued an Order granting the prayer for the issuance of a writ of preliminary injunction:

The Order restrained petitioner (and his agents) from entering or passing on the property and interfering with the improvements being constructed by the respondents.
The issuance of the writ was subjected to the posting of a bond amounting to P50,000.00 to cover potential damages if later determined that the injunction was unjustified.

On 14 June 1999, the trial court formally issued the writ of preliminary injunction.
Subsequent filings by petitioner included:

An Urgent Motion for Reconsideration challenging the orders.
A motion for the inhibition of Judge Alejo, based on the allegation that the judge had improperly stated that he could not reverse his 9 June 1999 Order.

On 23 June 1999, the trial court denied petitioner’s motion for inhibition.

Court of Appeals Proceedings

Petitioner then filed a petition for certiorari and prohibition with the Court of Appeals (CA) under CA-G.R. SP No. 53627, assailing:

The 9 June 1999 Order (writ of preliminary injunction).
The writ of preliminary injunction itself.
The trial court’s Order of 23 June 1999 denying the motion for inhibition.

In its 23 April 2002 Decision:

The CA upheld the trial court’s orders, ruling that Judge Alejo exercised sound discretion in issuing the writ of preliminary injunction.
The CA found petitioner’s petition for certiorari to be prematurely filed, noting that his Urgent Motion for Reconsideration was still pending before the trial court.

Further, on 26 September 2002, the CA denied petitioner’s motion for reconsideration.

Issues Raised and Developments Leading to the Supreme Court Review

Petitioner raised two principal issues in his petition for review:

Whether the CA erred in ruling that the trial court did not commit grave abuse of discretion in issuing its orders (specifically the 9 June 1999 Order, the writ of preliminary injunction, and the 23 June 1999 Order).
Whether the CA erred in ruling that the petition for certiorari was prematurely filed.

Despite raising the issue regarding the denial of the motion for inhibition, petitioner’s memorandum failed to present any argument on this point, leading the Court to decline ruling on its merit.
Petitioner also argued that:

The respondents’ closure of a public road significantly impeded the progress of construction work on his house, adversely affecting the movement of delivery trucks and laborers.
The urgency of resolving these issues justified his filing of the petition for certiorari instead of waiting for the resolution of his pending Urgent Motion for Reconsideration.

In subsequent manifestations:

Respondents informed the Court that no resolution had been issued on the Urgent Motion for Reconsideration, as the records had already been forwarded by the trial court.
Petitioner acknowledged that no trial court resolution had been issued on his Urgent Motion for Reconsideration at the time the petition for certiorari was filed.

The general procedural rule, requiring the exhaustion of a motion for reconsideration before resorting to certiorari, formed an essential backdrop for the dispute.

Issues:

Whether the CA erred in ruling that the trial court did not commit grave abuse of discretion in issuing:

The 9 June 1999 Order enjoining petitioner from interfering with the respondents’ property.
The writ of preliminary injunction.
The 23 June 1999 Order denying petitioner’s motion for inhibition.

Whether the petition for certiorari filed by petitioner was premature:

Petitioner’s filing occurred while his Urgent Motion for Reconsideration was still pending before the trial court.
Whether the urgency claimed by petitioner justifies circumventing the required resolution of the pending motion.

The adequacy of petitioner’s memorandum in addressing all issues raised, including the alleged reversible error in denying the motion for inhibition.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. 155374) Core Legal Reasoning Model Expanded

Facts:

Case Digest (G.R. No. 155374) Expanded Legal Reasoning Model

Facts:

Issues:

Ruling:

Ratio:

Doctrine:

Case Digest (G.R. No. 155374)
Core Legal Reasoning Model

Expanded

Case Digest (G.R. No. 155374)
Expanded Legal Reasoning Model