G.R. No. 228898 , December 04, 2019
MAUNLAD HOMES, INC., N.C. PULUMBARIT, INC., N.C.P. LEASING CORPORATION AND NEMENCIO C. PULUMBARIT, SR., PETITIONERS, VS. UNION BANK OF THE PHILIPPINES, RESPONDENT.

FACTS

On July 5, 2002, Union Bank and Maunlad Homes entered into a Contract to Sell involving the Maunlad Shopping Mall in Malolos, Bulacan. The contract allowed Maunlad Homes to retain possession and collect rentals. Maunlad Homes defaulted on its monthly amortizations. Union Bank sent a Notice of Rescission on February 5, 2003, and later, on November 19, 2003, a demand letter to pay rentals and vacate the property. As demands were unheeded, Union Bank filed an ejectment case ( G.R. No. 190071 ) on February 19, 2004. In February 2004, Union Bank began interfering with mall operations, prompting Maunlad Homes to file an injunction case ( G.R. No. 179898 ) to prevent Union Bank from collecting rentals.
In the injunction case, the RTC granted a preliminary injunction on June 23, 2004. The CA reversed this, but the Supreme Court, in its December 23, 2008 Decision, reinstated the injunction and remanded the case to the RTC to resolve the issue of injunction, which involved determining the parties’ rights under the Contract to Sell. This Decision became final on December 29, 2010.
In the ejectment case, the MeTC initially dismissed the complaint for lack of jurisdiction. This was affirmed by the RTC and CA. However, the Supreme Court, in its August 15, 2012 Decision ( G.R. No. 190071 ), reversed the CA, ruled that the MeTC had jurisdiction, ordered Maunlad Homes to vacate the property and pay rentals, and remanded the case to the MeTC for determination of rental amounts. This Decision became final on February 14, 2013.
After the finality of the ejectment Decision, Union Bank moved to dismiss the still-pending injunction case on the ground of mootness. The RTC denied the motion, ruling that the ejectment Decision’s interpretation of the Contract to Sell was merely provisional to resolve possession, and the conclusive interpretation rested with the injunction suit. The CA reversed the RTC, dismissed the injunction complaint as moot, and held that the Supreme Court’s final ruling in the ejectment case had already resolved the rights under the contract. Maunlad Homes elevated the case to the Supreme Court.

ISSUE

Whether the Complaint for Injunction has been rendered moot and academic by the final and executory Decision in the ejectment case ( G.R. No. 190071 ).

RULING

Yes, the Complaint for Injunction has been rendered moot and academic. A case becomes moot when it ceases to present a justiciable controversy due to supervening events, or when no substantial relief can be accorded. The Supreme Court’s final and executory Decision in G.R. No. 190071 (the ejectment case) ordered Maunlad Homes to vacate the Maunlad Shopping Mall and pay rentals. This ruling was based on a definitive interpretation that Maunlad Homes’ default rendered the Contract to Sell ineffective, depriving it of the right to possess the property and, consequently, the right to collect rentals. Therefore, the very rights Maunlad Homes sought to protect through the injunction—possession and the right to collect rentals under the contract—had been conclusively adjudicated. No substantial relief could be granted in the injunction case, as the issue of possession and the underlying contract rights had been finally settled. The RTC committed grave abuse of discretion in not dismissing the injunction case. The Supreme Court denied the petition and affirmed the CA’s Decision and Resolution dismissing the injunction complaint.