GR 153925; (August, 2006) (Digest)
G.R. No. 153925 August 10, 2006
Food Terminal, Inc., Benito Salazar, Samuel Namanama and Brenda Rivera, Petitioners, vs. Shoppers Paradise FTI Corporation, Respondent.
FACTS
Petitioner Food Terminal, Inc. (FTI) entered into a 25-year lease contract with respondent Shoppers Paradise for a 10-hectare property. The contract stipulated that the area would be turned over in tranches, free from occupants. FTI delivered Tranche 1 and portions of Tranche 2. A portion of Tranche 2, however, was occupied by the Metro Manila Transit Corporation (MMTC) at the time of contracting, which Shoppers Paradise later took possession of after MMTC vacated. Disputes arose over rental payments, with Shoppers Paradise claiming it had fully paid, while FTI demanded unpaid rentals and threatened to terminate the lease and repossess the property.
Shoppers Paradise filed a complaint for breach of contract and injunction in the Regional Trial Court (RTC). The RTC granted a temporary restraining order and later a writ of preliminary injunction, enjoining FTI from padlocking or repossessing the leased premises pending resolution of the main case. FTI filed a petition for certiorari with the Court of Appeals (CA), arguing that the injunction was issued with grave abuse of discretion and alleging bias by the trial judge. The CA dismissed the petition, prompting this appeal.
ISSUE
Whether the Court of Appeals erred in upholding the RTC’s issuance of the writ of preliminary injunction and in not finding bias on the part of the trial judge.
RULING
The Supreme Court denied the petition and affirmed the CA decision. On the propriety of the injunction, the Court ruled that a preliminary injunction’s sole objective is to preserve the status quo pending litigation on the merits. The trial court did not commit grave abuse of discretion, as its determination was based on the need to prevent serious damage to either party while their conflicting claims on lease compliance and rental payments remained unresolved. The injunction aimed to avert the deleterious effects of padlocking or repossession, which could render a future judgment ineffectual.
Regarding the allegation of judicial bias, the Court held that bias must be proved by clear and convincing evidence. Petitioners failed to substantiate their claim beyond mere suspicion. The trial judge’s actions, including the issuance of the injunction based on the evidence presented, fell within her judicial discretion and did not demonstrate partiality. Consequently, there was no valid ground for her inhibition from the case.