Republic v. Maceren
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership and administration of the Bago Iñigo Estate, a parcel of land in Davao City. The Republic of the Philippines, through the Philippine Alien Property Administrator, acquired the estate. The National Abaca and other Fibers Corporation (NAFCO) was designated to administer it. Carlos Iñigo initiated a complaint against NAFCO, seeking to prevent them from stripping hemp from the estate, claiming he had taken possession under an agreement. NAFCO countered that they had not granted Iñigo possession and that tenants recognized NAFCO's administration. 2. Procedural History: In civil case No. 13, the Court of First Instance of Davao, presided over by Judge Fernandez, initially ruled that the Republic of the Philippines was the owner and NAFCO was in possession, dissolving a receivership. Carlos Iñigo appealed this decision. Subsequently, in civil case No. 558, Judge Maceren declared the heirs of Feliciano Iñigo as owners of the estate, obligating them to pay a debt to the Philippine National Bank and ordering the transfer of title. NAFCO appealed this decision. Judge Fernandez later modified his earlier decision in civil case No. 13, ordering the receiver to turn over possession to Carlos Iñigo, despite Iñigo's appeal being pending. Judge Maceren also ordered the immediate execution of his decision in civil case No. 558, despite NAFCO's objection and pending appeal. 3. The Petition: The Republic of the Philippines filed a petition for certiorari with preliminary injunction, seeking to annul the order of Judge Fernandez modifying his decision in civil case No. 13 and the decision and order of execution by Judge Maceren in civil case No. 558. The Republic argued these orders were issued with grave abuse of discretion and in excess of jurisdiction, particularly as they affected the Republic, the owner of the property, without its consent and while it was not a party to the proceedings. The petition also sought to prevent the enforcement of these orders. However, the Supreme Court found that appeals from both orders were already pending before the Court of Appeals, rendering the petition premature.
Issue(s)
Whether the Supreme Court should entertain a petition for certiorari to annul orders of the Court of First Instance when appeals from said orders have already been perfected and are pending before the Court of Appeals. Whether the orders of respondent judges, affecting the property owned by the Republic of the Philippines, were rendered with grave abuse of discretion and in excess of jurisdiction, particularly since the Republic was not a party to the proceedings.
Ruling
The Supreme Court dismissed the petition for certiorari without pronouncement as to costs and dissolved the preliminary injunction. The Court held that the issues raised in the petition were already pending before the Court of Appeals via perfected appeals, making the petition premature. The Court also noted that the issue of the Republic's intervention had been previously passed upon by the Supreme Court in a resolution denying a petition for mandamus.
Ratio Decidendi
On Issue 1: The Court held that the petition for certiorari was premature. It noted that the Republic, through NAFCO, had already perfected its appeals to the Court of Appeals from the orders of respondent judges in both Civil Case No. 13 and Civil Case No. 558. The purpose of these appeals was to have the said orders declared null and void on the merits. Consequently, it would be improper for the Supreme Court to act on a petition for certiorari that seeks the same relief and raises the same questions already submitted to the proper appellate court. Acting on the petition would usurp the appellate jurisdiction of the Court of Appeals and create a situation where the Supreme Court would be reviewing a matter pending before a lower appellate court. On Issue 2: Regarding the claim that the orders were issued with grave abuse of discretion and in excess of jurisdiction because they affected the Republic's property rights without its consent to be sued, the Court reiterated its stance on prematurity. The Court stated that whether the Republic was the real party in interest or if its interest was properly represented by NAFCO were questions to be determined in the main appeals pending before the Court of Appeals. The Court also referred to its prior resolution in G.R. No. L-4493, which denied a petition for mandamus concerning the Republic's intervention in Civil Case No. 558, holding that such questions should be raised on appeal. Therefore, the Supreme Court found it inopportune to act on these claims at that stage, as the case in chief was not before it but before the Court of Appeals. The Court emphasized that to act on the matter then would be premature.
Main Doctrine
The Supreme Court reiterated that a petition for certiorari under Rule 65 is a special civil action that lies only when a tribunal, board, or officer exercising judicial, quasi-judicial, or ministerial functions has acted without or in excess of its jurisdiction, or with grave abuse of discretion, and there is no appeal, nor any plain, speedy, and adequate remedy in the ordinary course of law. When an appeal has already been perfected and is pending before the Court of Appeals, a petition for certiorari raising the same issues is considered premature and improper, as the appellate court is the proper forum to pass upon the merits of the case and any alleged errors committed by the lower court.