G.R. No. 165403 ; February 27, 2006
INTERNATIONAL EXCHANGE BANK, Petitioner, vs. HON. COURT OF APPEALS, THE HON. ANTONIO M. ESTEVES, in his capacity as the Presiding Judge of RTC Branch V, Baguio City, and AYALA LAND INCORPORATED, Respondents.

FACTS

Ayala Land Inc. (ALI) purchased two parcels of land from Corporate Investment Philippines, Inc. (CIPI) via a Deed of Absolute Sale dated June 15, 2000, but did not immediately register the sale. Subsequently, International Exchange Bank (iBank) obtained a writ of preliminary attachment from the Makati RTC against CIPI in a sum of money case. The sheriff levied on the subject properties on May 18, 2001, as the titles were still in CIPI’s name. CIPI was later declared insolvent. ALI finally registered the 2000 Deed of Sale on September 6, 2002, and new titles were issued in its name, but they carried over the annotation of iBank’s levy. ALI then filed an action for Quieting of Title and sought a writ of preliminary injunction against iBank to prevent any execution sale.
iBank moved to dismiss, arguing that its registered levy was superior to ALI’s belatedly registered sale and that the lis pendens ALI annotated on the titles was an adequate remedy, making an injunction unnecessary. The RTC denied the motion to dismiss and granted ALI’s application for a preliminary injunction to maintain the status quo. The Court of Appeals affirmed this decision.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in affirming the RTC’s grant of a writ of preliminary injunction in favor of ALI.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion. The grant of a preliminary injunction is within the trial court’s sound discretion, and its primary purpose is to preserve the status quo pending litigation on the merits. The Court upheld the RTC’s reasoning that while the lis pendens protected ALI by warning potential buyers of the ongoing litigation, it would not physically prevent a disposition of the property. Such a disposition could lead to a change in the property’s character, possible development by a third party, and a multiplicity of suits, thereby causing irreparable injury not fully addressed by the lis pendens alone.
The RTC correctly exercised its discretion to prevent these potential complications and preserve the rights of the parties until a final determination of the main case on the validity of the titles and the competing claims of iBank (as attaching creditor) and ALI (as purchaser). The Supreme Court emphasized that certiorari is not a remedy for errors of judgment but only for jurisdictional errors. No such error was present, as the lower courts acted within their jurisdiction and based their orders on a rational assessment of the potential harm and the need to maintain the status quo.