Fernando v. Vasquez
REITERATIONFacts
The Antecedents: Lessees of market stalls at Folgueras Remnants Center in Tondo, Manila, filed an interpleader suit to determine the lawful owner. The Court of First Instance (CFI) declared Valentin A. Fernando (petitioner) as the owner, which was affirmed by the Court of Appeals (CA) and this Court. Subsequently, Pelagia Fernando Santos and her husband Pablo G. Santos (respondents), who occupied the second floor of the property, refused to vacate despite petitioner's demands. Petitioner filed an unlawful detainer case against them. Procedural History: The City Court ordered the spouses Santos to vacate and pay monthly compensation. The respondent spouses then filed a petition for prohibition in the CFI, assailing the City Court's jurisdiction over the unlawful detainer case, arguing they had been in adverse possession for over a year. The CFI judge ruled that the City Court lacked jurisdiction, deeming the proper action to be accion publiciana, and nullified the City Court proceedings. Petitioner attempted to appeal this CFI decision but his appeal was dismissed by the Supreme Court for failure to pay the docket fee on time. The Petition: Petitioner filed the present petition for certiorari before the Supreme Court, seeking to annul the CFI judge's decision. However, before the case was decided on the merits, the parties entered into an amicable settlement, wherein the respondent spouses vacated the premises. This settlement was presented to the Court of Appeals in a separate case between the same parties.
Issue(s)
Whether the respondent judge committed a grave abuse of discretion amounting to excess of jurisdiction in nullifying the proceedings of the City Court in the unlawful detainer case. Whether certiorari is the proper remedy given that an appeal was available and lost by the petitioner's fault. Whether the case has become moot and academic due to the amicable settlement between the parties.
Ruling
The petition for certiorari is dismissed. The Supreme Court held that the case has become moot and academic due to the amicable settlement between the parties, and that the issues raised by the petitioner were either errors of judgment, which are not reviewable by certiorari, or rendered moot by the settlement.
Ratio Decidendi
On the nature of the error and the remedy of certiorari: The Court reiterated the well-established principle that certiorari is an extraordinary remedy available only to correct errors of jurisdiction or grave abuse of discretion amounting to excess of jurisdiction, not mere errors of judgment. An error of judgment, which involves the incorrect application of law or facts within the court's jurisdiction, is correctible only by appeal. The respondent judge had jurisdiction to render the decision in the prohibition case; any mistake made was in the exercise of that jurisdiction, thus constituting an error of judgment. Therefore, certiorari was not the proper remedy. On the availability of appeal: The Court emphasized that certiorari is generally not available when an appeal, a plain, speedy, and adequate remedy, exists. The petitioner had the right to appeal the CFI decision, and he did attempt to do so. However, his appeal was dismissed by the Supreme Court due to his failure to pay the docket fee on time. Having lost his right to appeal through his own fault, he could not use certiorari as a substitute for the lost appeal. The Court noted that exceptions to this rule exist, but none were applicable to the present case. On the effect of the amicable settlement: The Court found that the amicable settlement entered into by the parties, which stipulated that the respondent spouses would vacate the premises and the petitioner would retain the tenants, had the effect of res judicata. This settlement rendered all related judicial proceedings, including the unlawful detainer case, the prohibition case, and the present certiorari petition, moot and academic. To nullify the CFI judge's decision would be an idle ceremony, as the underlying dispute had been resolved by the parties themselves. The Court stated that it is not its function to decide purposeless questions that no longer exist.
Main Doctrine
A petition for certiorari will not lie to correct an error of judgment, which is appealable, but only errors of jurisdiction or grave abuse of discretion amounting to excess of jurisdiction. Furthermore, a case that has become moot and academic due to an amicable settlement between the parties, which has the effect of res judicata, will be dismissed.