Enriquez v. Rivera
REITERATIONFacts
1. The Antecedents: The underlying dispute involves a landlord-tenant relationship between spouses Florentino and Adelina Enriquez (lessees) and spouses Nestor and Estrella Mijares (lessors). The Enriquezes failed to pay monthly rentals for a residential house with a store from November 1975 to February 1976. Following demands from the Mijares, an ejectment case was filed in the Municipal Court of Angono, Rizal. 2. Procedural History: In the Municipal Court, the Enriquezes filed motions to dismiss, which were denied. They were subsequently declared in default, and the court proceeded to receive evidence ex-parte. The Municipal Court eventually rendered a decision in favor of the Mijares, ordering the Enriquezes to vacate and pay back rentals, damages, and attorney's fees. The Enriquezes appealed this decision to the Court of First Instance (CFI) of Rizal. Concurrently, the Enriquezes filed a petition for certiorari, prohibition, and preliminary injunction in the CFI, challenging the Municipal Court's actions, including the amendment of the complaint, denial of their motion to dismiss, and declaration of default. The CFI issued a restraining order. However, the CFI later dismissed the certiorari petition, deeming it moot and academic due to the pending appeal of the ejectment case. The Enriquezes appealed this dismissal to the Court of Appeals, which certified the case to the Supreme Court. 3. The Petition: This case reaches the Supreme Court on appeal from the Court of Appeals' certification. The petitioners-appellants, the Enriquezes, are contesting the dismissal of their petition for certiorari. They argue that their petition for certiorari was not rendered moot and academic by their appeal of the ejectment case. The Supreme Court is tasked with determining whether a petition for certiorari is indeed rendered superfluous by a perfected appeal in the same case, considering the provisions of Rule 65, Section 1 of the Rules of Court, which generally requires the absence of an appeal or other adequate remedy for certiorari to be available.
Issue(s)
Whether the perfection of an appeal in the ejectment case renders a pending petition for certiorari challenging the proceedings in the same ejectment case moot and academic. Whether the Court of First Instance erred in dismissing the petition for certiorari.
Ruling
The Supreme Court affirmed the order of the Court of First Instance dismissing the petition for certiorari.
Ratio Decidendi
On the issue of whether the perfection of an appeal renders a pending petition for certiorari moot and academic: The Court held that a petition for certiorari is rendered moot and academic by the perfection of an appeal in the same case. Rule 65, Section 1 of the Rules of Court provides that certiorari may be filed when there is no appeal, or any plain, speedy, and adequate remedy in the ordinary course of law. Since an appeal was perfected in the ejectment case, the condition for filing a certiorari petition was not met. The Court emphasized that certiorari is a remedy of last resort, intended to keep inferior tribunals within their jurisdiction or to prevent grave abuse of discretion amounting to excess of jurisdiction. It is not available to correct errors of procedure or mistakes in findings of fact or conclusions of law, which are proper subjects of an appeal. The existence of an appeal, which is a plain, speedy, and adequate remedy, precludes the grant of certiorari. Therefore, the appeal in Civil Case No. 117 rendered the petition for certiorari in Civil Case No. 23625 moot and academic, as the latter had lost its raison d'etre. On the issue of whether the Court of First Instance erred in dismissing the petition for certiorari: The Court found no error in the dismissal. The general rule is that certiorari will not lie as a substitute for an appeal. The exception, where certiorari may be available despite an appeal, is when the appeal is not a speedy and adequate remedy, or in cases of null and void orders, or when public welfare and broader interests of justice require it. None of these exceptional circumstances were present in this case. The perfection of the appeal in the ejectment case meant that the proper remedy was to pursue the appeal, not to maintain a parallel certiorari proceeding. To persevere with the certiorari petition would be an unnecessary and redundant enterprise, frowned upon by law. Thus, the dismissal of the certiorari petition was the correct course of action.
Main Doctrine
A petition for certiorari is rendered moot and academic by the perfection of an appeal in the same case, as certiorari is a remedy of last resort and is not available when an appeal or other plain, speedy, and adequate remedy exists.