Abogaa v. Go Sam
REITERATIONFacts
1. The Antecedents: The underlying dispute involves a charge against Go Sam for violating Commonwealth Act No. 444, the Eight Hour Labor Law. Concurrently, Eulogio Abogaa, Martin de Cenon, and Roman Maratas filed a civil complaint against Go Sam seeking recovery of overtime wages and one month's salary. 2. Procedural History: The criminal case for the violation of Commonwealth Act No. 444 was delegated to the justice of the peace court of Pasig. While this case was pending, the civil case (No. 970) was filed in the court of first instance of Rizal. Go Sam moved to dismiss the civil case due to a pending action between the same parties, which was granted by the respondent court. Subsequently, Go Sam was acquitted in the criminal case. The petitioners then moved to revive the civil complaint, but this motion was denied by the respondent court, which reasoned that the acquittal in the criminal case extinguished any civil liability. A motion for reconsideration was also denied. 3. The Petition: The petitioners are seeking a writ of certiorari and mandamus to annul and set aside the respondent court's order denying their motion to reinstate the civil complaint. They contend that the respondent court committed a grave abuse of discretion in denying the motion and pray that the court be compelled to reinstate the complaint, require Go Sam to answer, and proceed to trial on the merits.
Issue(s)
Whether the respondent court committed a grave abuse of discretion in denying the motion to reinstate the civil case after the acquittal of the defendant in the criminal case. Whether certiorari and mandamus are the proper remedies when an appeal is available.
Ruling
The petition for a writ of certiorari and mandamus is denied. The order of the respondent court denying the motion to reinstate the complaint in civil case No. 970 is sustained.
Ratio Decidendi
On Issue 1: The Court held that even if the denial of the motion to reinstate the complaint in civil case No. 970 was erroneous, it could not be corrected by certiorari. This is because the petitioners had a clear and adequate remedy through an appeal from the order, which was considered final and not interlocutory. The extraordinary legal remedy of certiorari is a prerogative writ that does not lie when an appeal was available to the aggrieved party, as repeatedly ruled by the Supreme Court. The denial, therefore, did not constitute a grave abuse of discretion that would warrant the intervention of a writ of certiorari. On Issue 2: The Court reiterated the well-established principle that certiorari is not a substitute for appeal. The extraordinary writ of certiorari is reserved for situations where there is no other plain, speedy, and adequate remedy in the ordinary course of law. Since the petitioners had the remedy of appeal from the order denying their motion to reinstate the civil case, they were bound to pursue that remedy. Resorting to certiorari when an appeal is available is improper and will lead to the dismissal of the petition, as it bypasses the prescribed procedural mechanisms for correcting judicial errors.
Main Doctrine
The Supreme Court reiterated that a petition for a writ of certiorari under Rule 65 of the Rules of Court is not a substitute for an appeal. The extraordinary remedy of certiorari is only available when there is no other plain, speedy, and adequate remedy in the ordinary course of law. If an appeal is available, it must be availed of, even if the petitioner believes it to be less speedy or adequate.