G.R. No. L-37427, June 25, 1974
CHEMPLEX (PHILIPPINES) INC. and TOMMY P. S. LIM, petitioners, vs. HON. RAMON C. PAMATIAN, BENIGNO D. LIM, CARMEN L. LIM, AQUILES J. LOPEZ and SIXTO T. ANTONIO, respondents.

FACTS

The case originated from an intra-corporate dispute within Chemplex (Philippines) Inc. (EPC). The private respondents, who were defendants in the lower court, filed a motion for the issuance of a writ of preliminary injunction. After conducting hearings and receiving evidence on this incident, the respondent Judge, the late Ramon C. Pamatian of the Court of First Instance of Rizal, issued an order dated August 29, 1973, granting the writ.
Petitioners Chemplex and Tommy P.S. Lim challenged this order via a petition for certiorari before the Supreme Court. They alleged grave abuse of discretion on the part of the trial judge. The petition led to extensive pleadings, with the parties submitting voluminous documents and annexes. The Supreme Court had previously issued a temporary restraining order on September 11, 1973, to halt the proceedings in the lower court pending its resolution of the certiorari petition.

ISSUE

Whether the respondent Judge committed grave abuse of discretion in issuing the writ of preliminary injunction, thereby warranting the grant of the petition for certiorari.

RULING

The Supreme Court En Banc dismissed the petition for certiorari for lack of merit and lifted the temporary restraining order. The Court held that there was no showing of grave abuse of discretion on the part of the respondent Judge. The legal logic is anchored on the nature of certiorari and the limited scope of the Supreme Court’s review over interlocutory orders like the grant of a preliminary injunction.
The Court emphasized that a writ of certiorari under Rule 65 is a remedy for correcting errors of jurisdiction, not errors of judgment. For it to lie, the abuse of discretion must be grave, patent, and arbitrary. In this case, the respondent Judge issued the injunction only after conducting due hearings and receiving relevant evidence on the factual circumstances necessitating injunctive relief. His findings were reasoned and based on judicial inquiry. The Supreme Court is not a trier of facts; it cannot re-evaluate the evidence and substitute its own factual conclusions for those of the trial court, especially when the facts are still contested and the main case is pending trial on the merits. To do so would be to preempt the primary function of the lower court. The issuance was provisional and subject to the outcome of the full trial. Consequently, no grave abuse of discretion was apparent from the order itself.
The Court unanimously directed the respondent court to act on the principal case with reasonable dispatch. Furthermore, a majority of the Court (with the Chief Justice dissenting on this point) suggested that the lower court consider the advisability of appointing a receiver to preserve the corporate assets and protect all shareholders’ interests during the litigation’s pendency.