Cantelang v. Medina
REITERATIONFacts
The Antecedents: Petitioners, defendants in several forcible entry and illegal detainer cases filed by Hillcrest Realty Corporation (HILLCREST) with the Municipal Court of Taytay, Rizal, alleged possession of the subject land as part of the Don Mariano San Pedro y Esteban Estate, with their possession exceeding ten years. Procedural History: During the hearings, the defendants' counsel manifested inhibition due to an ex-parte motion to consolidate filed by one of the defendants. The Municipal Court allowed HILLCREST to present evidence ex-parte. Despite a resetting to give defendants their day in court, they did not appear, leading the court to consider their right to adduce evidence waived and submit the case for decision. The Municipal Court rendered judgments in favor of HILLCREST, ordering the defendants to vacate, pay attorney's fees, monthly compensation, actual damages, and costs. These decisions became final and executory due to the defendants' failure to appeal. Writs of execution and demolition were subsequently issued. Petitioners then filed a complaint in the Court of First Instance (CFI) of Rizal seeking to annul HILLCREST's certificates of title and declare themselves legal owners. The Petition: Petitioners filed a Petition for Certiorari, Prohibition, and/or Mandamus with the Supreme Court, seeking to nullify the Municipal Court's decision and subsequent orders of execution and demolition, and to restrain the respondent judge from taking cognizance of the ejectment cases. They contended that the Municipal Court committed grave abuse of discretion amounting to lack or excess of jurisdiction by taking cognizance of the ejectment cases, arguing that the proper remedy for HILLCREST was an action for recovery of possession or ownership in the CFI.
Issue(s)
Whether the Municipal Court committed grave abuse of discretion amounting to lack or excess of jurisdiction in taking cognizance of the ejectment cases, rendering judgment thereon, and issuing the orders of execution and demolition. Whether the filing of an action to annul titles in the CFI justifies holding in abeyance the execution of a final and executory judgment in an ejectment case.
Ruling
The petition is dismissed. Costs are charged to Counsel Atty. Fernando V. Domingo, who is ordered to reimburse the same to his clients, the petitioners herein.
Ratio Decidendi
On the issue of grave abuse of discretion and jurisdiction: The Supreme Court held that the Municipal Court did not commit grave abuse of discretion. The allegations in the ejectment complaints, which stated that HILLCREST was the owner supported by titles and that petitioners forcibly entered the premises, conferred jurisdiction upon the Municipal Court. HILLCREST presented overwhelming evidence to establish its ownership and possession. Petitioners, on the other hand, failed to appear at the trial to prove their claims and, crucially, failed to appeal the adverse decision. The Court reiterated that certiorari is limited to correcting defects of jurisdiction and cannot be used to defeat the right to execution of a valid and final judgment. Errors of law, such as issues of ownership and possession, should be raised in an appeal, not through certiorari. Since petitioners failed to avail of adequate remedies in the ordinary course of law, such as a motion for reconsideration, new trial, or appeal, and lost these remedies through their own fault or negligence, certiorari cannot be used as a substitute. On the issue of holding execution in abeyance: The Court found the petitioners' contention that the filing of an action to annul titles in the CFI justified holding in abeyance the execution of the Municipal Court's decision to be without merit and a dilatory maneuver. The Municipal Court's decisions had become final and executory. The filing of a separate action to question the titles did not automatically stay the execution of a final judgment in an ejectment case. The Court emphasized that it would not lend support to efforts to annul proceedings that were regular and valid, especially when such efforts were aimed at defeating the execution of a final judgment. The Court also admonished counsel for filing a manifestly unmeritorious petition, which caused petitioners to incur unnecessary expenses and burdened the Court.
Main Doctrine
Certiorari cannot be used as a substitute for an appeal that was lost due to the petitioner's own fault or negligence. Errors of law, such as issues of ownership and possession, must be raised in an appeal and do not constitute jurisdictional errors correctable by certiorari. Furthermore, the filing of an action to annul titles does not automatically stay the execution of a final and executory judgment in an ejectment case.