G.R. No. 183869 - Villalon vs. Lirio

Lirio, the respondent, and Semicon Integrated Electronics Corporation (Semicon) entered into a lease contract covering properties in Pasig City.
Leonardo L. Villalon, the petitioner, acted as Semicon’s representative, serving as its president and chairman of the board, and executed the contract on behalf of Semicon.

Prior to the lease expiration, Semicon terminated the lease and allegedly left unpaid rentals, damages, and interest.
Lirio demanded the payments and, upon receiving no compliance from Semicon or Villalon, filed a complaint on May 17, 2005, seeking the sum of money and a preliminary attachment.
In his complaint, Lirio claimed that Semicon and Villalon unjustly pre-terminated the lease while also alleging that Villalon fraudulently and surreptitiously removed Semicon’s equipment, merchandise, and other effects from the leased premises—thereby depriving Lirio of his right to take inventory and secure his preferred lien over these properties.

Villalon filed a motion to dismiss on the ground that the complaint failed to state a cause of action against him, contending that as merely a corporate officer, he was not a real party-in-interest.
The RTC granted Villalon’s motion to dismiss, holding that due to the doctrine of separate corporate personality, only Semicon, as the lessee, was liable, and the dispute was confined to the contractual relationship between Semicon and Lirio.
Lirio’s subsequent motion for reconsideration was denied by the RTC.

Lirio filed a petition for certiorari under Rule 65 of the Rules of Court, challenging both the RTC’s dismissal order and its denial of reconsideration.
The CA nullified the RTC’s dismissal order, ruling that the trial court “gravely abused its discretion” by failing to consider that the case might properly invoke the doctrine of piercing the corporate veil.
The CA emphasized that Villalon’s active role in removing and transferring Semicon’s properties deprived Lirio of his preferred lien, thereby suggesting potential personal liability.

Villalon, however, argued that the order granting his dismissal was final and appealable, asserting that a petition for certiorari under Rule 65 is only proper when there is no plain, speedy, and adequate remedy available in the ordinary course of law.
Villalon maintained that Lirio should have pursued an appeal against the RTC’s dismissal rather than resorting to a petition for certiorari.

Whether Lirio’s resort to a petition for certiorari under Rule 65 was proper given that an appeal was available against the RTC’s dismissal order.
Whether the remedy of appeal would have been plain, speedy, and adequate, thereby precluding the use of an extraordinary writ for certiorari.

Whether the complaint sufficiently stated a cause of action against Villalon.
Whether the allegations of fraud, specifically that Villalon surreptitiously and fraudulently removed Semicon’s merchandise, effects, and equipment, were stated with the required particularity to pierce the corporate veil and impose personal liability.