Nicolas v. Castillo
REITERATIONFacts
The Antecedents: Petitioners Valeriano Nicolas and Socorro San Jose entered into a tenancy contract with respondent Reynaldo Nael for the cultivation of an 8-hectare riceland for the agricultural year 1950-51, with a sharing basis of 75% for the tenant and 25% for the landlords. In March 1951, Nael filed a complaint against petitioners for the recovery of his share of the harvest. Petitioners counterclaimed for damages, alleging that due to Nael's negligence, the harvest was only 76 cans (19 cavanes). The case was certified to the Court of Industrial Relations (CIR). Procedural History: Attorney Benedicto Bonifacio was commissioned by the CIR to receive evidence. Respondent Nael failed to appear at the hearing, and petitioners presented their evidence on their counterclaim. The CIR set another hearing to give Nael another chance, designating the Justice of the Peace of Sipocot to receive evidence, with the previous evidence of petitioners remaining on record. The case was repeatedly postponed and finally tried before Judge Vicente Tuason. On May 31, 1954, the CIR rendered judgment finding the harvest to be 76 cavanes and ordering petitioners to deliver Nael's share. Petitioners filed a petition for review in the Supreme Court (G.R. No. L-7939), which was dismissed for raising a factual question. The Petition: Petitioners filed this petition for certiorari under Rule 67, alleging that the CIR decision was based only on a portion of the evidence and failed to consider the evidence presented before Commissioner Benedicto Bonifacio, constituting grave abuse of discretion. They claimed the decision omitted the hearing before Commissioner Bonifacio, described Nael's evidence as "uncontroverted" despite their evidence, and that the physical condition of the records indicated the proceedings before Commissioner Bonifacio had not yet been transcribed when the decision was rendered.
Issue(s)
Whether the respondent Court of Industrial Relations, in rendering its decision, considered the entirety of the evidence presented by the parties. Whether the failure to file a motion for reconsideration in the lower court bars a petition for certiorari.
Ruling
The petition for certiorari is dismissed. Costs are against the petitioners.
Ratio Decidendi
On the issue of whether the respondent Court considered the entirety of the evidence: The Court held that the mere failure to mention the proceedings before Commissioner Bonifacio in the decision's narration of facts is not proof that the CIR was unaware of them, especially since the presiding judge had commissioned the commissioner. The transcript of the hearing before Judge Tuason also contained references to the proceedings before Commissioner Bonifacio, making it unlikely they were ignored. The term "uncontroverted" was likely used in the sense of "not sufficiently overcome" rather than "uncontradicted," as there was evidence presented by petitioners that, while not convincing the Court, did counter Nael's evidence. Furthermore, even if the decision was based solely on the evidence presented before Judge Tuason, petitioners were not prejudiced, as the evidence presented before both commissioner and judge was substantially the same regarding the core issue of the harvest quantity. The physical condition of the records did not conclusively prove that the transcript of the first hearing was unavailable when the decision was rendered. On the issue of whether failure to file a motion for reconsideration bars a petition for certiorari: The Court affirmed the settled doctrine that a writ of certiorari will be denied if the relief sought could have been obtained by application in the court of original proceedings and was not so applied for. This requires calling the lower court's attention to its supposed error and asking for correction through a motion for reconsideration. Since the petitioners failed to file a motion for reconsideration in the CIR, giving it an opportunity to correct any alleged errors or irregularities, the writ of certiorari must be denied on this ground alone.
Main Doctrine
A petition for certiorari will be denied if the petitioner failed to file a motion for reconsideration in the lower court to give it an opportunity to correct its alleged errors or irregularities.