Title
Metro Rail Transit Development Corp. vs. Trackworks Rail Transit Advertising, Vending and Promotions, Inc.
Case
G.R. No. 204452
Decision Date
Jun 28, 2021
MRTDC and Trackworks dispute over advertising contract termination; RTC Makati's interference with RTC Pasig's jurisdiction deemed void by Supreme Court, upholding judicial stability.

Case Summary (G.R. No. 204452)

Applicable Law and Key Dates

The case is governed primarily by the 1987 Philippine Constitution and procedural rules under the Rules of Court, specifically Rule 65 (Petition for Certiorari) and Rule 36 (Motion for Reconsideration). Key dates include the BLT Agreement executed on August 8, 1997; the original advertising services contract on October 27, 1998; and significant lower court and appellate dispositions occurring between 2010 and 2013, culminating in the Supreme Court decision dated June 28, 2021.

Background of Contracts and Dispute

In 1997, MRTDC entered into a Build-Lease-and-Transfer Agreement with the Department of Transportation and Communication (DOTC) for Phase 1 of MRT-3. Subsequently, MRTDC contracted Trackworks in 1998 to manage advertising services for a five-year term, extendable to ten years in 2005 with increased financial obligations. Trackworks defaulted on payments amounting to over PHP 276 million by 2009. MRTDC formally demanded payment and, citing contractual provisions, terminated the contract on September 1, 2009.

Proceedings Before the Regional Trial Courts and Arbitration

Trackworks filed a complaint in the RTC of Pasig City seeking to enjoin MRTDC from terminating the contract, requesting preliminary injunctive relief. The RTC denied the injunction but ordered the parties to submit to arbitration, staying court proceedings pending the arbitral award. Trackworks then moved for injunctive relief and filed a Petition for Certiorari, Prohibition, and Mandamus under Rule 65 in the RTC of Makati City, which granted a temporary restraining order initially but later denied the preliminary injunction. Jurisdictional conflicts arose between the RTCs of Pasig and Makati as both entertained different but related controversies.

Jurisdictional Conflict and Doctrine of Judicial Stability

The RTC of Makati’s October 22, 2010 Omnibus Order and December 20, 2010 Order, and subsequent June 14, 2012 Decision, which granted injunctive relief to Trackworks, directly conflicted with the earlier orders of the RTC of Pasig denying injunctive relief. The Court emphasized the “doctrine of judicial stability,” which prohibits a court from interfering with the regular orders or judgments of a coordinate court of concurrent jurisdiction. The RTC of Makati’s actions were deemed to have violated this doctrine as it nullified the RTC of Pasig’s orders.

Court of Appeals Decisions and Shift in Stance

MRTDC petitioned the Court of Appeals (CA) via a Petition for Certiorari, which initially, on July 30, 2012, granted the petition and annulled the RTC of Makati’s orders and decision. However, upon Trackworks’ motion for reconsideration, the CA reversed itself in a November 9, 2012 Resolution, dismissing the petition on the ground that the RTC of Makati’s June 14, 2012 Decision had already been rendered, which rendered the certiorari petition moot as an ordinary appeal was then an available remedy.

Issue on Mootness and Remedy Adequacy

The primary legal issue was whether the Petition for Certiorari filed by MRTDC before the CA was rendered moot by the subsequent June 14, 2012 Decision of the RTC of Makati. MRTDC argued that the June 14 decision was not final because they had filed a timely motion for reconsideration abating its finality, thus certiorari was proper to question jurisdictional errors. Conversely, Trackworks contended that the existence of a final RTC decision made certiorari inappropriate and that MRTDC’s remedy was to pursue an appeal.

Supreme Court’s Analysis on Certiorari and Extraordinary Remedies

The Supreme Court reiterated that certiorari under Rule 65 is an extraordinary remedy available only when the court or tribunal acted without or in excess of jurisdiction or with grave abuse, and when no adequate legal remedy by appeal exists. Although the subsequent RTC decision rendered the certiorari petition apparently moot, exceptions apply—such as when orders are null and void or where public interest and justice dictate.

Application of Doctrine Against RTC of Makati’s Jurisdiction

The Court held that the RTC of Makati had no jurisdiction over Trackworks' petition because the same subject matter and parties were already pending before the RTC of Pasig. The filing of a similar case constituted litis pendentia, a condition which precludes duplication and vexation in the courts. The orders and decisions of the RTC of Makati were therefore null and void for lack of jurisdiction. This was a fundamental violation of the doctrine of judicial stability, affirming that coordinate courts cannot interfere with each other's rulings within ongoing cases.

Doctrine of Litis Pendentia and Res Judicata

The Court found that the two actions involved substantially identical parties, rights, and reliefs

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