CHIQUITA BRANDS v. OMELIO

CHIQUITA BRANDS vs. GEORGE E. OMELIO
G.R. No. 189102
June 7, 2017


Facts:

On Aug 1993, thousands of banana plantation workers instituted a class suit in US for damages against 11 foreign corporations, Chiquita brands being one of those 11 companies. The claimants claimed to have been exposed to dibromochloropropane (DBCP) while working in the plantation. As a result, these workers suffered serious and permanent injuries to their reproductive system.

However US courts dismissed the complaint based on forum non conveniens.
On May 1996, the claimants filed a complaint on the same 11 corporations in the RTC of Panabo City, Davao. Before pre-trial the petitioner and the claimants entered into a compromise agreement with the claimants. The agreement states that; the petitioner shall be release from all or their obligation after they deposited an escrow amount in favor of the claimant which would be administered by a third person/ mediator.
The RTC of Panabo approved the compromised agreement and dismissed the petition of the claimant.

After dismissal of the civil claim the claimants moved for the execution of the compromise agreement.

The petitioner opposed the execution on the ground of mootness; they argued that they had already complied with their obligation by depositing the settlement amount into an escrow account.

However, RTC of Panabo granted the motion for execution because there was no proof that they have fulfilled their obligation.

On May 2003 petitioner filed a motion to suspend the execution and be allowed to present evidence on their behalf.

During the hearing of the case, the claimants picketed outside the court room and accused the RTC judge of Panabo as a corrupt official who delayed the execution. Petitioner requested for change of venue and was granted.

The case was transferred and now under the jurisdiction of the RTC of Davao city.
On July 2009, the RTC of Davao city through Judge Omelio ordered the execution of the compromised agreement.

Aggrieved by the RTC’s decision, the petitioner filed for a petition for certiorari even without a prior appeal to the CA.

Petitioner allege that the respondent Judge committed grave abuse of discretion in issuing the writ of execution and ordering them to directly pay each of the claimant contrary to the compromise agreement between petitioner and claimant.


Issue:

WON the hierarchy of courts was violated when the petitioner filed for certiorari without appealing first to the CA.

WON Judge Omelio committed grave abuse of discretion.



Held:

1. No. Under the principle of hierarchy or courts, direct recourse to the SC is improper because SC is a court of last resort and must remain to be so in order for it to satisfactorily perform its constitutional functions.

Nonetheless, the invocation of the SC’s original jurisdiction to issue writs of certiorari has been allowed in certain instances on the ground of special and important reasons clearly stated in the petition, such as, 1. When dictated by public welfare and advancement of public policy, 2. When demanded by broader interest of justice, 3. Where the challenged orders were patent nullities or 4. When analogous exceptional and compelling circumstances called for and justified the immediate and direct handling of the case.
In the case at hand, it was clearly stated that the case is in need of a broader interest of justice, as it may prejudice any or both parties when delayed.

2. Yes. Courts can neither amend nor modify the terms and conditions of a compromise validly entered into by the parties. A writ of execution that varies the respective obligation of the parties under a judicially approved compromise settlement is void. Hence Judge Omelio committed grave abuse of discretion.