G.R. No. 168062 - Victorias Milling Co., Inc. vs. Court of Appeals

On March 4, 2004, petitioner Victorias Milling Co., Inc. (VMC) filed a complaint for unlawful detainer and damages before the Municipal Circuit Trial Court (MCTC) of E.B. Magalona-Manapla, Negros Occidental, docketed as Civil Case No. 392-M.
The summons was served on March 10, 2004 on Danilo Maglasang, IPI’s Human Relations Department Manager.
On March 19, 2004, respondent International Pharmaceuticals, Inc. (IPI) filed its Answer, expressly reserving its right to challenge the jurisdiction of the MCTC over its person due to alleged improper service of summons.
IPI also submitted an Omnibus Motion for Hearing of Affirmative Defenses and moved to suspend the proceedings.

On August 30, 2004, the MCTC issued an order denying IPI’s motion to suspend the proceedings and, pursuant to the Rule on Summary Procedure, set the case for a preliminary conference scheduled on September 29, 2004.
A motion for reconsideration was later filed by IPI and subsequently denied, affirming the trial court’s handling of the case.

IPI filed a petition for certiorari with the Court of Appeals (CA) challenging the jurisdiction of the MCTC, focusing on technical defects in service and arguing that the petition was properly filed notwithstanding the summary procedure requirements.
The CA directed petitioner VMC to file its comment on February 22, 2005, to which IPI responded, and VMC later filed a rejoinder.
Meanwhile, in the MCTC proceedings, after a preliminary conference was terminated, the parties were ordered to submit affidavits, witness evidence, and position papers.

The CA issued a resolution on May 6, 2005 ordering the issuance of a writ of preliminary injunction. This injunction enjoined the MCTC from proceeding with Civil Case No. 392-M and interfered with IPI’s possession of the leased premises during the pendency of the case.
The resolution conditioned the injunction on the posting of an injunction bond of ₱200,000 to cover any potential damages should the CA ultimately rule against IPI.
Petitioner VMC opted not to file a motion for reconsideration of the CA’s resolution, arguing that it was patently null and void and that it effectively delayed the summary proceedings, and instead immediately filed a petition for certiorari directly challenging the CA’s action.

Petitioner VMC contended that the petition for certiorari filed by IPI was barred by Section 13 of Rule 70 of the Rules on Civil Procedure and the Rule on Summary Procedure, which aim to expedite disposition of ejectment cases without regard to technicalities.
VMC argued that the CA’s issuance of the writ of preliminary injunction disrupted the intended speedy resolution of the ejectment suit and that the petition filed by IPI should have been dismissed outright.
In contrast, respondent IPI maintained that the procedural misstep regarding the service of summons, although technical, created a void that justified equitable relief and the issuance of the injunction, citing precedent (including Go v. Court of Appeals) to support its position.

Whether the service of summons on IPI’s Human Relations Manager, instead of on the proper party, violates the procedural requirements under the Rules on Civil Procedure, thereby affecting the trial court’s jurisdiction over IPI.

Whether IPI’s petition for certiorari and prohibition, challenging the MCTC’s interlocutory order in an ejectment case, is barred by the explicit provisions of Section 13 of Rule 70 of the Rules on Civil Procedure.
Whether the CA exceeded its jurisdiction by allowing the petition and issuing a writ of preliminary injunction despite the summary nature of the proceedings.

Whether the CA gravely abused its discretion by entertaining a petition for certiorari that is categorically prohibited in ejectment cases.
Whether the issuance of the injunction, which resulted in delaying the speedy resolution of the ejectment case, constitutes an excess in the CA’s jurisdiction.