Case Summary (G.R. No. 173259)
Factual Background and Initial Proceedings
Respondents claimed ownership over a parcel of land and constructed a passageway facilitating access to Barangay Que Grande Street, which they allowed neighboring property owners, including the petitioner, to use. In March 1999, the respondents, intending to build commercial establishments, fenced the area, effectively blocking the original passage but creating an alternative route. In May 1999, however, the petitioner, accompanied by armed personnel, forcibly demolished the fence, allegedly with the assistance of Rolando Lim, the Officer In Charge of the City Engineer's Office.
Trial Court Orders and Responses
On May 24, 1999, the Regional Trial Court of Valenzuela City, presided by Judge Floro P. Alejo, scheduled a hearing regarding a temporary restraining order (TRO) at the request of the respondents. On June 9, 1999, the court issued an order granting a writ of preliminary injunction to prevent the petitioner from entering the property or interfering with ongoing constructions, contingent upon the respondents posting a bond of P50,000. Following the issuance of this injunction, the petitioner contested the trial court's decision through an Urgent Motion for Reconsideration.
Motion for Inhibition and Subsequent Orders
Subsequently, the petitioner filed a motion for the inhibition of Judge Alejo, alleging bias based on previous statements by the judge. This motion was denied by the trial court on June 23, 1999. Displeased by these decisions, the petitioner escalated the matter to the Court of Appeals through a petition for certiorari, challenging both the writ of preliminary injunction and the orders of the trial court.
Court of Appeals Ruling
On April 23, 2002, the Court of Appeals upheld the trial court’s orders, confirming that Judge Alejo had acted within his discretion in granting the preliminary injunction. The Court noted that a hearing had indeed been conducted prior to the issuance of the injunction, contesting the petitioner’s claim of a lack of due process. The appellate court also found the petition prematurely filed, as the petitioner had not awaited the trial court’s ruling on the Urgent Motion for Reconsideration.
Supreme Court's Overview and Conclusion
Upon further appeal to the Supreme Court, the petitioner posed several questions regarding the alleged grave abuse of discretion by the Court of Appeals and the trial court's rulings. The Supreme Court noted the doctrine that a motion for reconsideration is a prerequisite before seeking certiorari, barring certain exceptions not applicable in this instance. Consequently, the Court affirmed the appellat
...continue readingCase Syllabus (G.R. No. 173259)
Background of the Case
- The case originated from an action for Injunction with Damages, with a request for a preliminary injunction or temporary restraining order.
- The respondents, Emmanuel B. Juan and Carmelita Juan Delos Santos, alleged they were the registered owners of a parcel of land in Barangay Ugong, Valenzuela City.
- They developed a passage over this land to connect with Barangay Que Grande Street, allowing neighboring property owners, including the petitioner, Dr. Antonio C. Santos, to utilize it.
- In March 1999, the respondents decided to construct commercial buildings on their land, which led them to fence the area and close the original passage.
- A new passage was subsequently opened on another side of their property, maintaining access to the barangay road.
Events Leading to the Dispute
- In May 1999, the petitioner, allegedly supported by armed men, demolished the concrete fence that blocked the old passage, which the respondents claimed was done without any court order and with the assistance of Rolando Lim, the Officer In Charge of the City Engineer's Office of Valenzuela City.
- Following this incident, the respondents sought judicial relief, which prompted the trial court to issue orders regarding the temporary restraining order and preliminary injunction.
Orders by the Trial Court
- An initial order was issued by Judge Floro P. Alejo on May 24, 1999, setting a hearing for the temporary restraining order on May 27, 1999.
- On May 27, 1999, the trial court ordered both parties to submit position papers and supporting documents wit