G.R. No. 193415 ; April 18, 2012
SPOUSES DAISY and SOCRATES M. AREVALO, Petitioners, vs. PLANTERS DEVELOPMENT BANK and THE REGISTER OF DEEDS OF PARAÑAQUE CITY, Respondents.

FACTS

Petitioners Spouses Arevalo obtained a loan from respondent Planters Development Bank, secured by a mortgage on their property. Due to their failure to pay, the Bank initiated extra-judicial foreclosure proceedings. To enjoin the auction sale, the spouses filed a complaint (First Complaint) seeking nullification of interests and penalties, alleging the Bank breached the loan agreement through illegal schemes that caused their default. They applied for a writ of preliminary injunction. The trial court, citing Section 2 of the Supreme Court’s Procedure on Foreclosure, required them to first pay 12% per annum interest on the principal obligation as a precondition for the writ’s issuance. The spouses argued this rule only applied if unconscionable interest was alleged, which they claimed was not their case, as their complaint focused on the Bank’s withholding of loan releases. They did not comply with the payment order, and no injunction was issued.
Meanwhile, the trial court dismissed the First Complaint for lack of cause of action. The spouses appealed this dismissal. Simultaneously, they filed a Rule 65 petition with the Court of Appeals (CA) assailing the orders denying the injunction. The CA affirmed the trial court, ruling the spouses’ challenge to the interest charges—using terms like “manifestly unjust” and “void ab initio”—equated to an allegation of unconscionability, thus triggering the payment requirement. The spouses then filed this Rule 45 Petition. During these proceedings, they also filed a Second Complaint seeking nullification of the mortgage and foreclosure sale.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s denial of the application for a writ of preliminary injunction for failure to pay the 12% interest as required under the Procedure on Foreclosure.

RULING

The Supreme Court denied the petition, rendering it moot and finding petitioners guilty of forum-shopping. The petition was moot because the main action (the First Complaint) upon which the injunction application was based had already been dismissed by the trial court. An injunction is merely a provisional remedy ancillary to a principal action; with the dismissal of the main case, the issue of the injunction’s propriety was rendered academic. The legal logic is that courts will not determine moot questions or abstract propositions, as a judgment on such issues cannot provide any actual relief.
Furthermore, the Court found the spouses engaged in willful forum-shopping. They pursued three simultaneous remedies involving the same essential facts and reliefs: (1) the Rule 65 petition (subject of this appeal) on the injunction denial, (2) an appeal of the dismissal of the First Complaint, and (3) the filing of a Second Complaint. This trifurcation of actions constituted a clear attempt to secure a favorable ruling from different fora, which is prohibited as it abuses court processes, degrades the administration of justice, and can lead to conflicting judgments. The dismissal of the petition, with prejudice, was warranted on this independent ground.