G.R. No. 171681 ; September 11, 2009
KEI MARIE ABRERA, et al., minors represented by their parents, Petitioners, vs. HON. RODOLFO A. PONFERRADA, in his capacity as Presiding Judge of Branch 95, Regional Trial Court of Quezon City, and PHILIPPINE INTERNATIONAL LIFE INSURANCE CO., INC., Respondents.

FACTS

Numerous minor petitioners, represented by their parents, filed a Petition for Corporate Rehabilitation on behalf of Philippine International Life Insurance Co., Inc. (Philinterlife). They alleged to be owners of Philinterlife educational plans and claimed the company was insolvent. The Regional Trial Court (RTC) issued a Stay Order, appointing a Rehabilitation Receiver and enjoining actions against Philinterlife. Subsequently, Philinterlife itself, through its Board of Directors, filed a separate Petition for Corporate Rehabilitation, which the RTC also accepted.
The RTC then issued an Order consolidating the two rehabilitation cases. The minor petitioners filed a Motion for Reconsideration, arguing their petition was filed first and that Philinterlife’s own petition was a sham filed in bad faith to wrest control from the legitimate planholders. The RTC denied their motion. The petitioners elevated the case via a Petition for Certiorari under Rule 65, arguing the RTC committed grave abuse of discretion in consolidating the cases and in effectively recognizing Philinterlife’s petition over theirs.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in issuing the Order consolidating the rehabilitation petition filed by the minor planholders with the subsequent petition filed by Philinterlife itself.

RULING

No, the RTC did not commit grave abuse of discretion. The consolidation of the two petitions was a proper exercise of judicial prerogative aimed at avoiding multiplicity of suits and ensuring the efficient, economical, and expeditious administration of justice. The court’s power to consolidate cases under Section 1, Rule 31 of the Rules of Court is discretionary and warranted when actions involve a common question of law or fact.
The legal logic is clear: both petitions fundamentally seek the same relief—the rehabilitation of Philinterlife. They involve identical parties and hinge on the same central question: the financial status and viability of the corporation. Consolidation promotes uniformity in decision-making and prevents conflicting rulings. The petitioners’ claim of grave abuse of discretion fails, as such abuse implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. The RTC’s order was based on a rational legal ground (judicial efficiency) and was within its sound discretion. The mere fact that the petitioners filed first does not create an absolute right to preclude a subsequent filing by the corporate debtor itself, especially when the ultimate objective of both proceedings is congruent. The proper recourse for aggrieved parties is to actively participate in the consolidated proceedings to protect their interests.