Case Summary (G.R. No. 186720)
Factual Background
In 1996, the Spouses Meritus Rey Medado (the Spouses) entered into a Deed of Sale with Assumption of Mortgage with the Estate of Antonio Consing, represented by Soledad Consing, to acquire a property in Cadiz City, identified as Hacienda Sol. The transaction involved a loan obligation with the Philippine National Bank (PNB) which the Spouses Medado assumed. Subsequently, the Estate of Consing offered the same lots to the government under the Department of Agrarian Reform's Voluntary Offer to Sell program. In 2000, the Estate of Consing filed a case for rescission and damages against the Spouses, claiming they breached the terms of their agreement.
Civil Case for Injunction
While the rescission case was ongoing, the Spouses Medado initiated Civil Case No. 797-C, an action for injunction against the Land Bank of the Philippines (LBP) to prevent it from releasing proceeds from the Voluntary Offer to Sell to the Estate of Consing. They sought a temporary restraining order and a writ of injunction against both the LBP and the estate. The Regional Trial Court (RTC) granted the Spouses' application on March 9, 2007.
Appeal to the Court of Appeals
The heirs of Antonio Consing appealed the RTC's order, arguing it constituted forum shopping as it violated the principle against litis pendentia since a similar case was ongoing. The Court of Appeals (CA) found that the issuance of the RTC’s order was a grave abuse of discretion, leading to a decision on September 26, 2008, that nullified the RTC's order and dismissed the injunction complaint.
Issues for Determination
The issues before the Supreme Court included whether the CA erred in admitting the petition for certiorari despite alleged deficiencies, whether the CA invalidated the necessity of a motion for reconsideration, and whether the filing of the injunction complaint violated the forum shopping rule.
Court's Ruling on Deficiencies in Certification
The Supreme Court determined that the CA had ample grounds to accept the petition despite claims of defects in the verification and certification against forum shopping. The Court highlighted that the challenges regarding the signing of the certification and the use of a community tax certificate instead of a government-issued ID did not constitute a failure of substantive compliance.
Motion for Reconsideration
It was affirmed that the CA did not err in accepting the certiorari petition without a prior motion for reconsideration since it was established that such motion would have been rendered moot by the actions taken by the RTC, thus justifying the resort to the special civil action.
Forum Shopping Analysis
The Supreme Court concluded that the requirements for forum shopping were present, as both actions were based on significantly similar facts and claims concerning the same parties. The in
...continue readingCase Syllabus (G.R. No. 186720)
Nature of the Case
- The case is a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure.
- The petitioner seeks to annul and set aside the Court of Appeals (CA) Decision dated September 26, 2008, which reversed the Regional Trial Court (RTC) order granting writs of preliminary prohibitory and mandatory injunction.
- The CA also denied the motion for reconsideration of the said decision in a Resolution dated January 21, 2009.
Factual Background
- In 1996, Spouses Meritus Rey Medado and Elsa Medado (Spouses Medado) acquired property in Cadiz City from the Estate of the late Antonio Consing through Deeds of Sale with Assumption of Mortgage.
- The properties involved were covered by specific land titles (OCT No. P-498, TCT Nos. T-31275, T-31276, and T-31277).
- Spouses Medado assumed the estate’s loan with Philippine National Bank (PNB).
- Subsequently, the estate offered the lots to the government under the Department of Agrarian Reform’s Voluntary Offer to Sell (VOS) program.
- The Estate of Consing filed an action for rescission and damages against Spouses Medado, PNB, and the Register of Deeds, alleging failure to meet agreement conditions.
- Meanwhile, Land Bank of the Philippines (LBP) issued a certificate of deposit to the Estate of Consing as compensation for the lots under the VOS program.
- Spouses Medado fear LBP would release the full proceeds to the estate, which they claimed was unjustified as they had acquired the properties earlier.
- Spouses Medado instituted an injunction action (Civil Case No. 797-C) to restrain LBP from releasing VOS proceeds to the Estate and to compel LBP to release the funds to them.
Trial Court Proceedings
- On March 9, 2007, the RTC of Cadiz City granted Spouses Medado’s application for issuance of preliminary prohibitory and mandatory injunctions.
- The RTC ordered LBP to withhold release of VOS proceeds to the heirs and release the funds to Spouses Medado upon posting of a bond.
Court of Appeals Ruling
- The heirs of the late Consing challenged the RTC order via a petition for certiorari before the CA.
- The CA ruled that the RTC gravely abused its discretion and nullified the March 9, 2007 order.
- It dismissed the injunction complaint for violation of the rule against forum shop