G.R. No. L-80902 August 31, 1988
BENGUET CORPORATION, INC., petitioner, vs. COURT OF APPEALS (NINTH DIVISION), VICTOR LA’O, CECILIA LA’O, ELVIRA LA’O and PERU REALTY CORPORATION, respondents.

FACTS

The dispute involves a property in Forbes Park, Makati, originally owned by Peru Realty Corporation (PERU) and sold to Benguet Corporation (BENGUET) with a right to repurchase. After PERU failed to repurchase, BENGUET filed a consolidation case (Civil Case No. 43502) which was settled by a compromise agreement approved by the court. PERU again failed to redeem, leading to the issuance of titles in BENGUET’s name. The La’O family, residing on the property, leased it from BENGUET but refused to vacate after the lease expired. Consequently, BENGUET secured a writ of preliminary mandatory injunction from the Regional Trial Court (RTC) in a separate reconveyance case (Civil Case No. 5815) filed by PERU and the La’Os, ordering the latter to vacate.
Simultaneously, PERU and the La’Os filed a petition with the Court of Appeals 10th Division (CA-G.R. SP No. 10387) seeking to annul the judgment in the consolidation case. The 10th Division dismissed this petition on May 29, 1987, but a motion for reconsideration remained pending. Following this dismissal, the RTC enforced the writ of mandatory injunction, including a break-open order. PERU and the La’Os then filed a new petition with the Court of Appeals 9th Division (CA-G.R. SP No. 12964) challenging the RTC’s break-open order. BENGUET moved to transfer this new 9th Division case to the 10th Division, but the 9th Division denied the motion, prompting BENGUET’s petition for certiorari to the Supreme Court.

ISSUE

Whether the Court of Appeals 9th Division committed grave abuse of discretion in denying BENGUET’s motion to transfer CA-G.R. SP No. 12964 to the 10th Division.

RULING

Yes, the Supreme Court ruled that the 9th Division committed grave abuse of discretion. The legal logic centers on judicial efficiency and the prevention of conflicting rulings. Although the 10th Division had dismissed CA-G.R. SP No. 10387, the motion for reconsideration was still pending, meaning the case was not yet final. The 9th Division erroneously considered it terminated. Crucially, the subject of the 9th Division case—the implementation of the break-open order and mandatory injunction—was a direct consequence of the 10th Division’s decision that dismissed the petition to annul the compromise judgment. Therefore, the issues in both petitions were intimately and substantially related, involving the same property, parties, and underlying facts.
Consolidation of related cases before a single division is imperative to ensure consistent adjudication and avoid protracted litigation from potentially contradictory resolutions. The Supreme Court emphasized that the rationale for consolidation is to have all intimately related cases acted upon by one court division to prevent conflicting decisions on common questions of law and fact. Denying the transfer under these circumstances undermined judicial efficiency. Accordingly, the Supreme Court granted certiorari, set aside the 9th Division’s resolutions, and ordered the transfer and consolidation of CA-G.R. SP No. 12964 with the still-pending matter in the 10th Division.