Title
Victorias Milling Co., Inc. vs. Court of Appeals
Case
G.R. No. 168062
Decision Date
Jun 29, 2010
VMC sued IPI for unlawful detainer; CA issued injunction despite certiorari prohibition. SC nullified CA's ruling, emphasizing summary procedure's expeditious nature.

Case Summary (G.R. No. 199710)

Factual Antecedents

On March 4, 2004, VMC filed a complaint against IPI for unlawful detainer, which was assigned as Civil Case No. 392-M. Summons was served to IPI's Human Relations Department Manager on March 10, 2004. IPI's formal response included an express reservation concerning the MCTC’s jurisdiction due to improper service of summons, followed by a motion for suspension of proceedings.

Ruling of the Municipal Circuit Trial Court

The MCTC, on August 30, 2004, denied IPI’s motion for suspension, proceeding instead to schedule a preliminary conference. IPI filed for reconsideration, which was subsequently denied.

Ruling of the Court of Appeals

In response to the MCTC's refusal to suspend proceedings, IPI filed a petition for certiorari with the CA questioning the MCTC's jurisdiction over its person. On May 6, 2005, the CA issued a resolution that allowed for the issuance of a writ of preliminary injunction, thus halting the MCTC's proceedings and maintaining IPI's possession of the leased premises until further orders.

Issues Raised by Petitioner

VMC contends that the CA acted with grave abuse of discretion by issuing an injunction based on a prohibited petition, arguing that the CA should have dismissed the petition outright based on established procedural rules and emphasized the hierarchy of courts.

Petitioner’s Arguments

VMC argues that the petition for certiorari filed by IPI is disallowed under Section 13 of Rule 70 of the Rules of Court. VMC asserts that the CA should have outright dismissed the petition, emphasizing that procedural rules are in place to ensure expedient resolution of ejectment cases without unnecessary delays. Petitioner also points out that IPI has not demonstrated a clear right to the property in question.

Respondent IPI's Arguments

IPI counters that the Summary Procedure was not intended to hinder juristic principles, asserting that a procedural void justified the CA's actions in issuing the injunctive writ. IPI insists that its situation is similar to a previously adjudicated case, arguing for an equitable remedy rather than immediate dismissal.

Court's Ruling

The Court ruled in favor of VMC, emphasizing that no procedural void existed that warranted the issuance of a certiorari petition or the granting of an injunction. It reitera

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