Facts:

• Triplex Enterprises, Inc. sought to annul a land sale contract.
• The sale involved two parcels of land in Tagaytay City, sold by PNB-Republic Bank to Solid Builders, Inc.
• Triplex claimed the sale was invalid due to the absence of Board of Directors' approval as mandated by Board Resolution No. 000231-1993.
• This resolution required Board approval for sales exceeding P3 million.
• After losing a bid for the land, Triplex hired Atty. Romeo Roque, a real estate broker, who sought a legal opinion from the Office of the Government Corporate Counsel (OGCC).
• The OGCC opined that the lack of Board approval rendered the sale contract unperfected.
• During the trial, Triplex attempted to present Atty. Roque's testimony regarding the OGCC's opinion, but the respondents objected based on attorney-client privilege.
• The trial court upheld the objection, prompting Triplex to file a petition for certiorari with the Court of Appeals, which was dismissed.
• Triplex subsequently escalated the issue to the Supreme Court.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled against Triplex, denying the petition for review on certiorari.
• The Court upheld the findings of the Court of Appeals, stating that the trial court did not commit grave abuse of discretion in excluding Roque's testimo...(Unlock)

Ratio:

• Certiorari is a special civil action applicable only when a tribunal acts without or in excess of its jurisdiction or with grave abuse of discretion.
• The writ of certiorari is not a remedy for every erroneous interlocutory order; it is limited to extraordinary cases where lower court actions are wholly void.
• Errors in the application of law or appreciation of evidence do not deprive a...continue reading