Philippine Air Lines v. Teodoro
REITERATIONFacts
The Antecedents: Petitioners Philippine Air Lines, Inc. (PAL) and Far Eastern Air Transport, Inc. (FEATI) were defendants in Civil Case No. 1865 before Branch II of the Court of First Instance (CFI) of Negros Occidental, filed by Capitol Subdivision, Inc. (Capitol) for compensation for land use within Airport No. 2 of Bacolod City. Prior to this, in Civil Case No. 444, an identical issue regarding compensation for land use within the same airport was decided by the same respondent judge. Civil Case No. 597, involving a similar claim for land use within the airport, was filed by Andres Wenches against PAL and FEATI and assigned to Branch III of the same CFI. Procedural History: Petitioners moved to transfer Civil Case No. 1865 to Branch III for joint trial with Civil Case No. 597, arguing common questions of law and fact, and that the respondent judge, having decided Civil Case No. 444, might have formed an adverse opinion. The motion was denied, as was a motion for reconsideration. Petitioners then filed the instant petition for certiorari and mandamus. The Petition: Petitioners prayed for a writ of preliminary injunction to restrain the hearing of Civil Case No. 1865, and for judgment setting aside the order denying their motion to transfer and annulling rulings refusing to allow certain witnesses to testify on the inconsistency of a letter and the worthlessness of a document as evidence. They also sought to compel the respondent judge to transfer Civil Case No. 1865 for joint trial with Civil Case No. 597 and to admit the specified testimonies.
Issue(s)
Whether the respondent judge committed a grave abuse of discretion or exceeded his jurisdiction in denying the motion to transfer Civil Case No. 1865 for joint trial with Civil Case No. 597. Whether the respondent judge committed a grave abuse of discretion in sustaining objections to certain questions propounded by petitioners' counsel during the hearing of Civil Case No. 1865.
Ruling
The petition is dismissed. The writ of preliminary injunction is dissolved.
Ratio Decidendi
On the issue of transferring Civil Case No. 1865 for joint trial: The Court held that Rule 32, Section 1 of the Rules of Court, which allows for joint hearing or consolidation of actions involving common questions of law or fact, grants discretion to the court. This discretionary power is incompatible with the clear legal duty required for a writ of mandamus. Furthermore, the rule pertains to cases before the same judge, not cases pending before different branches of the same court, as no judge has control over cases pending before another branch. The Court also noted that the petition for certiorari and mandamus was filed long after the hearing on the merits of Civil Case No. 1865 had commenced, and ordering a transfer would result in a judge deciding the case without having observed the witnesses' demeanor, a situation that should be avoided. Therefore, the first issue was decided in favor of the respondents. On the issue of sustaining objections to evidence: The Court ruled that the respondent judge had jurisdiction over Civil Case No. 1865 and the authority to receive evidence and rule on objections. Any errors in these rulings are reviewable only on appeal, not through certiorari, unless there was a grave abuse of discretion amounting to lack of jurisdiction. The Court found that the records did not provide sufficient facts to determine the materiality or propriety of the objected questions, and expressing an opinion might preempt the lower court's decision on the merits. The Court cited Orient Insurance Co. vs. Revilla and People vs. Concepcion but found them not in point, as they involved situations where the lower court refused to perform a clear ministerial duty. In the present case, no such duty existed. The Court emphasized the policy of admitting evidence on doubtful objections, as stated in Prats & Co. vs. Phoenix Insurance Co., to avoid unnecessary delays and complications on appeal. The Court also noted that its decision in G.R. No. L-4958 (related to Civil Case No. 444) tended to broaden the perspective of the case, indicating possibilities the lower court should consider.
Main Doctrine
A writ of mandamus will not lie to compel a judge to transfer a case for joint trial when the Rules of Court grant discretion to the judge, and the transfer would result in a judge deciding a case without having observed the witnesses' demeanor. Certiorari will not lie to correct erroneous rulings on the admissibility of evidence if the judge has jurisdiction, as such errors are reviewable only on appeal.