Case Digest (G.R. No. 119769)
Facts:
Bernard Raymond T. Saulog, Virginia A. Saulog, Teodoro A. Saulog, Maura S. Aguinaldo, Susan Saulog, Melquiades A. Saulog, Lilia S. Venturina, Marietta S. Vergara, Dagupan Bus Co., Inc. and Saulog Transit, Inc. v. The Court of Appeals and Gamma Holdings Corp., G.R. No. 119769, September 18, 1996, Supreme Court First Division, Hermosisima, Jr., J., writing for the Court.On April 8, 1994, private respondent Gamma Holdings Corporation filed a complaint in the Regional Trial Court (Branch 101, Quezon City) against the individual petitioners (stockholders) and against Dagupan Bus Company, Inc. (DBC) and Saulog Transit, Inc. (STI). Gamma sought a temporary restraining order and a writ of preliminary injunction to enjoin the individual defendants from selling their shares and to enjoin the two bus companies from transferring, pledging, mortgaging or otherwise encumbering their assets; Gamma also prayed for specific performance of an alleged agreement to sell either the assets or the outstanding stock of the two companies and for damages. Gamma alleged negotiations beginning earlier that culminated in a May 13, 1993 meeting and the execution of documents denominated “Terms of DBC‑STI Sale” (Annexes A–A5), which it claimed bore signatures of the parties and of its representative Rene B. Azurin.
The RTC granted the requested temporary restraining order and, after submissions, issued an order dated April 29, 1994 granting a writ of preliminary injunction conditioned on a P500,000 bond; the court grounded its order largely on its finding that the “Terms of DBC‑STI Sale” bore the signatures of the parties and that factual issues (e.g., validity, rescission) required trial. The petitioners moved for reconsideration but later withdrew that motion and filed a petition for certiorari with the Court of Appeals, arguing the injunction lacked factual support and that public welfare considerations were ignored.
In a decision promulgated March 31, 1995, the Court of Appeals dismissed the petition for certiorari, holding that factual questions are generally not open in such a remedy and that it lacked jurisdiction to rule on the merits. The petitioners elevated the case to the Supreme Court via a Rule 45 petition for review on certiorari challenging the CA decision and the RTC order. The Supreme Court issued a temporary restraining order on August 18, 1995 against implementation of the CA and RTC rulings pending resolution of the petition. The peti...(Pro-only)
Issues:
- Did the Regional Trial Court properly exercise its discretion in issuing the writ of preliminary injunction?
- Did the Court of Appeals err in affirming the RTC order without balancing public policy, welfare, necessity and convenience against Gamma’s ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)