Republic v. Maglanoc
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership of Lot No. 20 in Aurora Cadastre. Eustacio de los Reyes claimed ownership based on possession since 1912, first by his predecessor Gregorio de los Reyes, and then by himself since 1917. The land was described as pasture land, occupied by the claimant, declared for taxation, and free from encumbrances. The Republic of the Philippines, through the Director of Forestry, contested this claim, alleging fraud and misrepresentation in the acquisition of the title. 2. Procedural History: Initially, an order of general default and a decision dated May 22, 1922, declared Lot No. 20 as public land. Subsequently, on April 21, 1961, the Court of First Instance of Quezon, upon petition by Eustacio de los Reyes and without opposition, set aside the previous order and decision concerning Lot No. 20, admitted de los Reyes' answer, and authorized the Deputy Clerk of Court to receive evidence. Following this, on May 26, 1961, the court rendered a decision adjudicating Lot No. 20 to Eustacio de los Reyes. The Bureau of Forestry filed a petition for relief from this decision and for reopening of the case in April 1962, which was denied by an order dated June 28, 1962. 3. The Petition: The Republic of the Philippines, through the Director of Forestry, filed a petition for certiorari on October 19, 1962, seeking to annul the orders and decision of the Court of First Instance of Quezon. The petition alleged abuse of discretion amounting to fraud, misrepresentation, and deceit by Eustacio de los Reyes. Specific allegations included failure to furnish a copy of the petition to the Director of Forestry, false claims about the filing of a claim and presentation of evidence in 1922, misrepresentation of possession as owner when the land was leased under a pasture permit, and falsely stating the land was uncontested despite a lease agreement. The Republic argued that these actions led to the erroneous adjudication of public land.
Issue(s)
Whether the respondent judge committed a grave abuse of discretion amounting to lack of jurisdiction in setting aside the 1922 order and decision and in adjudicating Lot No. 20 to Eustacio de los Reyes. Whether certiorari is the proper remedy given that the order denying the petition for relief had become final and was not appealed.
Ruling
The petition for certiorari is denied. The injunction previously issued is dissolved.
Ratio Decidendi
On Issue 1: The Court found that the petition for relief filed by Eustacio de los Reyes in 1961, which led to the setting aside of the 1922 order and decision, was granted under the provisions of Republic Act No. 931. This Act allowed for the reopening of cadastral cases under certain conditions. While the petitioner alleged fraud, misrepresentation, and deceit, these were the same grounds raised in the motion for relief that was denied by the respondent judge in June 1962. The Court held that it was too late to discuss these allegations as they were already passed upon by the lower court and the order denying the motion for relief was not appealed. On Issue 2: The Court held that the defense raised by the respondents was meritorious. Time and again, the Supreme Court has dismissed petitions for certiorari to annul decisions or orders which could have been appealed but were not. The petition for certiorari was filed to circumvent the remedy of appeal, as the issues raised were the same ones presented in the petition for relief. Since the order denying the petition for relief had become final due to the failure to appeal, certiorari could not be availed of as a substitute for the lost remedy of appeal. The Court emphasized that certiorari does not lie where the remedy by appeal has been lost.
Main Doctrine
The Supreme Court reiterated that a petition for certiorari is not a substitute for a lost appeal. The remedy of certiorari under Rule 65 of the Rules of Court is only available when there is no appeal, or any plain, speedy, and adequate remedy in the ordinary course of law. The Court emphasized that it has consistently dismissed petitions for certiorari aimed at annulling decisions or orders that could have been appealed but were not, particularly when the issues raised were already passed upon by the lower court and the order denying a petition for relief has become final due to failure to appeal.