G.R. No. 167533 ; July 27, 2007
AUDI AG, Petitioner, vs. HON. JULES A. MEJIA, in his capacity as Executive Judge of the Regional Trial Court, Alaminos City; AUTO PROMINENCE CORPORATION; and PROTON PILIPINAS CORPORATION, Respondents.

FACTS

Petitioner Audi AG, a foreign corporation not licensed to do business in the Philippines, was sued by respondents Auto Prominence Corporation and Proton Pilipinas Corporation in the Regional Trial Court (RTC) of Alaminos City for specific performance and injunction. The complaint alleged that Audi appointed Proton as its exclusive assembler and distributor of Audi cars in the Philippines under agreements dated 1996. Respondents claimed they made significant investments based on Audi’s representations, but Audi later excluded the Philippines from its ASEAN assembly strategy and, in 2004, sent a notice terminating the agreements. Respondents sought to enforce the agreements and applied for a Temporary Restraining Order (TRO).
Respondent Executive Judge Jules A. Mejia, prior to the raffle of the case to a permanent ponente, conducted a hearing on the TRO application. On March 29, 2005, he issued an Order granting a 20-day TRO, enjoining Audi from terminating the contracts. Audi filed a Petition for Certiorari directly with the Supreme Court, arguing the judge acted with grave abuse of discretion by issuing the TRO before raffle and for a 20-day period, allegedly violating procedural rules. Audi also challenged the judge’s subsequent Order denying a motion for inhibition.

ISSUE

Whether the Supreme Court should give due course to the Petition for Certiorari assailing the RTC’s issuance of the TRO and the denial of the motion for inhibition.

RULING

The Supreme Court dismissed the petition due to fatal procedural defects. First, petitioner Audi failed to file a motion for reconsideration of the assailed March 29, 2005 Order before resorting to certiorari. A motion for reconsideration is an indispensable condition for a special civil action for certiorari under Rule 65, as it affords the lower court an opportunity to correct its own error. The Court found no sufficient justification, such as extreme urgency or prevention of a miscarriage of justice, to excuse this omission.
Second, petitioner violated the doctrine of hierarchy of courts by filing the petition directly with the Supreme Court instead of with the Court of Appeals, the appropriate intermediate appellate body. The rule on hierarchy of courts is a procedural imperative to prevent overcrowding of the Supreme Court’s docket and to allow the lower courts to perform their assigned functions. Petitioner failed to advance any special and important reason to warrant a direct invocation of the Supreme Court’s original jurisdiction. The Court emphasized that procedural rules are not mere technicalities but are designed to ensure the orderly and speedy administration of justice.