GR 128743; (November, 1999) (Digest)
G.R. No. 128743 November 29, 1999
ORO CAM ENTERPRISES, INC., petitioner, vs. COURT OF APPEALS and ANGEL CHAVES, INC., respondents.
FACTS
Angel Chaves, Inc. filed an unlawful detainer case against several lessees, including Constancio Manzano, for failure to pay increased rentals after their lease contracts expired. The MTCC initially dismissed the complaint against Manzano and his business, Oro Cam Enterprises. However, the RTC reversed this on appeal, ordering the ejectment of all defendants. The Court of Appeals and subsequently the Supreme Court dismissed Manzano’s petition for review for being filed out of time, rendering the RTC decision final. When Angel Chaves moved for a writ of execution, Oro Cam Enterprises, claiming to be a separate corporate entity from the individual lessee Manzano, filed a petition for certiorari with the RTC to enjoin the execution. The RTC granted a preliminary injunction.
ISSUE
The primary issue is whether the Court of Appeals correctly annulled the RTC’s injunctive order that halted the execution of a final ejectment judgment against Oro Cam Enterprises.
RULING
The Supreme Court affirmed the Court of Appeals. The legal logic is twofold. First, on the substantive issue of identity, the Court ruled that Oro Cam Enterprises is not a separate party entitled to relief. The ejectment case was filed against Constancio Manzano, doing business under the name “Oro Cam Enterprises.” A trade name is not a separate juridical entity; it is merely the designation under which an individual conducts business. Therefore, the final judgment against Manzano is binding on the business name he used. Oro Cam Enterprises, Inc., the subsequently incorporated entity, cannot claim a distinct personality to evade the execution of a judgment that had already attained finality against its predecessor and namesake.
Second, on the procedural issue, the Court held that while a writ of preliminary injunction is generally an unappealable interlocutory order, certiorari is an available remedy when the order is patently erroneous and appeal is inadequate. The RTC’s injunction was patently erroneous because it interfered with the execution of a final and executory judgment. A preliminary injunction requires a clear legal right, which petitioner utterly lacked, as its right to occupy the premises had been definitively extinguished by the final RTC decision. The Court of Appeals, therefore, correctly exercised its certiorari jurisdiction to annul an order that unjustly deprived Angel Chaves, Inc. of the fruits of its final victory. The execution must proceed.