G.R. No. 175020 . October 4, 2007.
RURAL BANKERS ASSOCIATION OF THE PHILIPPINES, represented by FRANCIS S. GANZON and WILLIAM K. HOTCHKISS III, FRANCIS S. GANZON, and WILLIAM K. HOTCHKISS III, petitioners, vs. MA. ROSARIO TANGHAL-SALVAÑA, respondent.

FACTS

This case originated from an intra-corporate dispute concerning the 2006 election of the Board of Directors of the Rural Bankers Association of the Philippines (RBAP), a non-stock, non-profit organization. Respondent Ma. Rosario Tanghal-Salvaña, a candidate for Director for Region XII, filed a complaint before the Regional Trial Court (RTC) after the RBAP Electoral Board disqualified her and proclaimed Charles D. Tan as the sole qualified candidate. Salvaña alleged that the appointment of interim Electoral Board members by then-President William Hotchkiss violated the RBAP Election Code, which reserves that power to the Board. She further contended that Tan was ineligible as he represented Region X and was improperly endorsed.
The RTC denied Salvaña’s application for a preliminary injunction. On appeal, the Court of Appeals (CA) issued a Resolution granting a temporary restraining order and, subsequently, a writ of preliminary injunction, enjoining the newly elected board and officers from assuming office. The CA found that the RTC committed grave abuse of discretion, as Salvaña established a clear legal right and a material and substantial invasion of that right, given the serious questions regarding the validity of the Electoral Board’s composition and actions.

ISSUE

Whether the Court of Appeals erred in granting the writ of preliminary injunction.

RULING

The Supreme Court denied the petition, but not on the substantive merits of the injunction. The Court dismissed the petition due to the petitioners’ fatal procedural lapses. The petitioners, including RBAP as a co-petitioner, failed to attach certified true copies of the material portions of the record referred to in their petition, specifically the RTC Order dated June 23, 2006, which was assailed in the CA. Rule 45, Section 4(d) of the Rules of Court mandates that such copies must accompany the petition. The Court emphasized that the requirement is indispensable for the proper review of the case, as it allows the Supreme Court to verify the factual basis of the lower courts’ rulings.
The Court rejected the petitioners’ argument that the attached CA resolutions sufficiently presented the facts, stating that these resolutions merely summarized the RTC order but were not a substitute for the order itself. The petitioners’ inclusion of RBAP as a co-petitioner, despite it being the real party-in-interest and the entity whose corporate acts were being questioned, compounded the procedural defect. The Court held that obedience to procedural rules is essential for the orderly administration of justice. While rules may be relaxed under justifiable circumstances, the petitioners’ blatant disregard for fundamental requirements, without any explanation, warranted the petition’s dismissal. The RTC was ordered to proceed with the trial of the main intra-corporate case with deliberate dispatch.