Case Summary (G.R. No. 88373)
Procedural Background
On February 23, 1988, Ayer Productions filed a complaint in the Regional Trial Court of Makati (Civil Case No. 88-151) seeking a Temporary Restraining Order (TRO) and a writ of preliminary injunction against Enrile over claims of privacy infringement. The trial court issued a TRO the next day, and on March 16, 1988, it granted a writ of preliminary injunction prohibiting the production of the series. Enrile contended that the series infringed upon his rights and those of his family.
Court Proceedings and Rulings
Following the issuance of the preliminary injunction, Ayer Productions and McElroy filed their respective petitions for certiorari to challenge the court’s orders. The petitions were consolidated, and the Supreme Court granted a limited TRO allowing production to resume for portions of the mini-series that did not reference Enrile or his family. On April 29, 1988, the Supreme Court set aside the trial court’s injunction, ruling that Enrile had no cause of action for a preliminary injunction, reinforcing the right to free expression concerning the mini-series.
Subsequent Developments
After the Supreme Court’s decision became final on June 20, 1988, the case was dismissed by the Regional Trial Court on January 19, 1989. Subsequently, Ayer filed a motion to present evidence for damages incurred due to the wrongful issuance of the injunction, asserting losses amounting to 438,073 Australian Dollars. Enrile opposed this motion, arguing that the application for damages was untimely and that Ayer had forfeited any right to claim damages due to prior non-compliance with the injunction.
Issue of Timeliness for Damages Claim
The core legal question was whether Ayer’s claim for damages from the wrongful injunction was timely filed before the finality of the dismissal of the trial court's order. Ayer argued that the claim stemmed from the January 19, 1989 order, while Enrile contended that the judgment from the Supreme Court regarding the injunction was the relevant reference point for timing, which preceded the dismissal of the case, hence barring Ayer's claim.
Supreme Court's Conclusion
The Supreme Court ruled in favor of Enrile, declaring that Ayer's damages claim should have been filed before the judgment became final on June 20, 1988. The court concluded that the previous judgment had essentially resolved the matter on the merits, rendering the claim for damages void si
...continue readingCase Syllabus (G.R. No. 88373)
Case Background
- This case involves multiple petitions related to a dispute between Juan Ponce Enrile (Petitioner) and Ayer Productions Pty. Ltd. and others (Respondents) regarding the issuance of a preliminary injunction.
- The case is rooted in a complaint filed by Ayer Productions against Enrile, alleging a violation of privacy due to the production of the mini-series "The Four Day Revolution" without the consent of Enrile.
- The trial court initially granted a Temporary Restraining Order (TRO) and later a writ of preliminary injunction against the production of the mini-series.
Procedural History
- Enrile filed a complaint on February 23, 1988, requesting a TRO and a writ of preliminary injunction against Ayer Productions.
- The trial court issued an ex parte TRO on February 24, 1988, followed by a writ of preliminary injunction on March 16, 1988.
- Ayer Productions and Hal McElroy subsequently filed separate petitions for certiorari, seeking to overturn the trial court's injunction orders.
- The Supreme Court, in a decision issued on April 29, 1988, set aside th