Case Summary (G.R. No. 154623)
Procedural History
The Regional Trial Court (RTC) in Bacolod City issued a decision ordering Looyuko/NAMI to pay Multi-Luck based on their motion for judgment on the pleadings. Consequently, the RTC issued a writ of execution for the sale of properties owned by Looyuko/NAMI. Go filed for an injunction against the auction, claiming he was a business partner of Looyuko and had not been included in the original suit, thus believing he had the right to protect his interests as a co-owner.
Regional Trial Court Decisions
The RTC of Pasig City initially granted Go's request for a temporary restraining order and later issued a writ of preliminary injunction preventing the auction. The court denied Multi-Luck's motion to dismiss Go's complaint, which challenged the RTC's jurisdiction over the matter.
Court of Appeals Review
Multi-Luck subsequently elevated the case to the Court of Appeals (CA), which reviewed the decisions of the RTC. The CA ruled that the RTC had abused its discretion by granting the injunction, considering there was no clear legal right on Go's part to justify such relief. The CA opined that the Pasig RTC's intervention interfered unlawfully with the judgment of the Bacolod RTC, as it was a coordinate court exercising concurrent jurisdiction.
The Argument of the Petitioner
Go argued that he was a "stranger" to the original complaint (Civil Case No. 98-10404) and thus qualified as a "third-party claimant" under the Rules of Court. He contended that since he was not impleaded in the original case, the judgment rendered therein should not bind his property rights.
Legal Principles and Court’s Rationale
The court reiterated the principle that a court cannot interfere by injunction with the judgments or orders of another court of equal jurisdiction. As the Bacolod RTC had already acquired jurisdiction over the collection case and issued a final judgment, it retained exclusive jurisdiction to handle all proceedings related to its judgment. Therefore, the Pasig RTC's issuance of a preliminary injunction was deemed an overreach of its authority.
Requirements for Issuing a Preliminary Injunction
The decision also examined Go's failure to establish the requisite legal grounds for a preliminary injunction. It emphasized that one must show a clear and positive right that necessitates judicial protection to qualify for such relief. The court highlighted that injunctive relief cannot protect uncertain future rights nor can it be granted without proving an urgent and serious threat to a legally recognized interest.
Agreements Between Parties and Ownership Claims
Go presented agreements alleging his co-ownership of NAMI and related properties. Nonetheless, the
...continue readingCase Syllabus (G.R. No. 154623)
Case Overview
- This case involves a petition for review on certiorari filed by Jimmy T. Go against various respondents, including the Clerk of Court and Ex-Officio Provincial Sheriff of Negros Occidental, and Multi-Luck Corporation.
- The petition challenges a Decision dated April 30, 2002, and a Resolution dated July 31, 2002, of the Court of Appeals (CA), which reversed the Orders of the Regional Trial Court (RTC) of Pasig City granting a writ of preliminary injunction to the petitioner and denying the respondents' motion to dismiss.
Factual Background
- Multi-Luck Corporation initiated a collection suit against Alberto T. Looyuko, the sole proprietor of Noah's Ark Merchandising Inc. (NAMI), for the dishonor of three checks totaling P8,985,440.00.
- The Bacolod RTC ruled in favor of Multi-Luck, leading to the issuance of a writ of execution for the sale of Looyuko's properties.
- Petitioner Jimmy T. Go filed a complaint for injunction against the respondents, claiming co-ownership of the properties and alleging he was not a party to the initial collection suit, which violated his rights.
Procedural History
- The Pasig RTC initially issued a Temporary Restraining Order (TRO) and later a writ of preliminary injunction, preventing the auction of the properties.
- Multi-Luck's motions to dismiss and for reconsideration were denied.
- Multi-Luck subse