GR 204452; (June, 2021) (Digest)
G.R. No. 204452 , June 28, 2021
Metro Rail Transit Development Corporation, Petitioner, vs. Trackworks Rail Transit Advertising, Vending and Promotions, Inc., Respondent.
FACTS
Petitioner Metro Rail Transit Development Corporation (MRTDC) and respondent Trackworks Rail Transit Advertising, Vending and Promotions, Inc. (Trackworks) entered into a Contract for Advertising Services on October 27, 1998, renewed on March 11, 2005, for Trackworks to handle advertising along the EDSA MRT-3 line. Trackworks defaulted on its payment obligations. On April 1, 2009, MRTDC demanded payment of P276,978,072.42. After Trackworks failed to cure the default within 30 days as required by their contract, MRTDC sent a Notice of Termination on September 1, 2009.
On November 23, 2009, Trackworks filed a Complaint with Application for Temporary Restraining Order and/or Writ of Preliminary Injunction against MRTDC with the Regional Trial Court (RTC) of Pasig City (Civil Case No. 77291-PSG), praying for the parties to submit to arbitration and to restrain MRTDC from terminating the contract. On January 4, 2010, the Pasig RTC denied the application for preliminary injunction and ordered the parties to submit to arbitration, staying the court proceedings pending the arbitration award.
Subsequently, on April 28, 2010, Trackworks filed a Petition for Certiorari, Prohibition and Mandamus under Rule 65 before the RTC of Makati City (Civil Case No. 10-414), seeking to restrain MRTDC and others from acting on the termination. The Makati RTC, Branch 65, in its October 22, 2010 Omnibus Order and December 20, 2010 Order, denied MRTDC’s Motion to Dismiss and effectively granted Trackworks’ Application for a Writ of Preliminary Injunction.
MRTDC filed a Petition for Certiorari before the Court of Appeals (CA) assailing the Makati RTC orders. The CA, in its July 30, 2012 Decision, granted MRTDC’s petition, annulled the Makati RTC orders, and dismissed Civil Case No. 10-414, ruling that the Makati RTC violated the doctrine of judicial stability by interfering with the Pasig RTC’s orders and that litis pendentia existed. However, upon Trackworks’ Motion for Reconsideration, the CA issued a November 9, 2012 Resolution reversing its Decision, dismissing MRTDC’s Petition for Certiorari as moot because the Makati RTC had already rendered a Decision on June 14, 2012 in Civil Case No. 10-414, making the preliminary injunction permanent, and thus an ordinary appeal was the more adequate remedy.
Meanwhile, the Philippine Dispute Resolution Center, Inc. (PDRCI) issued a Final Arbitral Award on January 15, 2013 in favor of MRTDC, which was confirmed by the Pasig RTC. A writ of execution was issued on June 13, 2013 against Trackworks.
ISSUE
Whether the Petition for Certiorari filed by MRTDC before the CA has been rendered moot by reason of the June 14, 2012 Decision of the RTC of Makati City, Branch 65.
RULING
No. The Supreme Court granted the Petition, reversed and set aside the CA’s November 9, 2012 Resolution, and declared the June 14, 2012 Decision of the Makati RTC, the proceedings therein, and all orders issued, null and void for lack of jurisdiction.
The Court held that the CA erred in dismissing MRTDC’s certiorari petition as moot. The Makati RTC’s June 14, 2012 Decision was not yet final and executory, as an appeal was pending. More importantly, the Makati RTC had no jurisdiction over Trackworks’ Rule 65 petition. The Pasig RTC, in Civil Case No. 77291-PSG, had prior jurisdiction over the principal action and had ordered the parties to arbitrate. The Makati RTC’s assumption of jurisdiction through a special civil action for certiorari constituted an unjustified interference with the orders of a co-equal court, violating the doctrine of judicial stability. Furthermore, litis pendentia was present, as both cases involved the same parties, rights, and facts. The first action filed in Pasig was the appropriate vehicle. The subsequent finality of the arbitral award in favor of MRTDC, confirmed by the Pasig RTC, rendered any judgment in the Makati case a nullity. Thus, the CA should have affirmed its initial Decision annulling the Makati RTC’s orders.