Heirs of Inocencio Santiago v. Castro
REITERATIONFacts
The Antecedents: Petitioners, claiming to be heirs of Inocencio Santiago, sought to annul orders for the demolition of their houses, which stemmed from civil cases where private respondents, as registered owners, sued defendants (predecessors of petitioners) for unlawful occupation. The defendants' claim of ownership based on a Spanish title of Inocencio Santiago was rejected by the lower court, which ruled in favor of the plaintiffs, ordering the defendants to vacate and pay rentals, a judgment that became final and executory. In separate instances, Tan Cheng Leng filed cases against families occupying his property, leading to a demolition clearance from the NHA that was not implemented due to the area being covered by the Zonal Improvement Program (ZIP). Spouses Ramon Albert and Maria Puno also sought the ejectment of occupants from their land, resulting in a demolition clearance from the NHA after the City Mayor's recommendation and a Kasunduan executed by 22 of the 28 families to vacate voluntarily. Procedural History: Petitioners filed a petition for certiorari to annul orders from respondent Judges Jose P. Castro and Antonio P. Solano, claiming these orders were issued with grave abuse of discretion and beyond jurisdiction. Judge Castro's order directed the demolition of illegally constructed houses, and he also dismissed a petition for prohibition filed by Francisco Edades, et al. against Tan Cheng Leng, et al., stating no cause of action and failure to exhaust administrative remedies. Later, on September 23, 1982, Judge Castro issued an order directing the demolition of petitioners' structures. Judge Solano dismissed a petition for prohibition, quieting of title with preliminary injunction, deeming it moot and academic, and also dismissed a petition for prohibition and quieting of title filed by the Heirs of Inocencio Santiago against the NHA, et al., finding it insufficient in form and substance, with the application for a writ of preliminary injunction denied as moot and academic. A restraining order was issued by the Supreme Court, enjoining demolition. The Petition: Petitioners sought to annul the orders of Judges Castro and Solano, asserting grave abuse of discretion and lack of jurisdiction. They also aimed to annul demolition notices issued by the City Engineer of Quezon City, alleging that 22 houses not party to the original cases were demolished without due process and that their claims based on the Spanish title of Inocencio Santiago were disregarded. Furthermore, petitioners claimed that after the demolition, respondents pursued the redemolition of salvaged structures.
Issue(s)
Whether the orders of respondent Judges Castro and Solano were issued with grave abuse of discretion and beyond their jurisdiction. Whether the demolition of structures belonging to individuals not parties to the original cases was conducted without due process. Whether the petition for certiorari was the proper remedy, considering the existence of an appealable order and the finality of the questioned orders. Whether the issues raised in the petition have become moot and academic.
Ruling
The petition is dismissed. The temporary restraining order issued on October 19, 1982, is dissolved.
Ratio Decidendi
On the propriety of the orders of respondent Judges Castro and Solano: The Court noted that respondent Judge Jose P. Castro had dismissed the petition for prohibition in Civil Case No. Q-32452 on June 13, 1981, for stating no cause of action and failure to exhaust administrative remedies. Similarly, respondent Judge Antonio P. Solano dismissed the petition for prohibition and quieting of title in Civil Case No. Q-35920 on August 27, 1982, for being insufficient in form and substance. The application for a writ of preliminary injunction was denied as moot and academic. The Court found that these orders, having become final and executory, could not be subject to a petition for certiorari. On the demolition of structures and validity of registered titles: The Court reiterated that the properties in question were registered and titled in the names of private respondents. It referenced the ruling in Benin vs. Tuason, which held that a document presented as a Spanish title by the predecessors-in-interest of the petitioners did not establish ownership and was unavailing against the valid Transfer Certificate of Title of J.M. Tuason & Co., Inc. and Original Certificate of Title No. 735. Therefore, the petitioners, claiming as heirs of Inocencio Santiago, could not derogate the validity of these registered titles and had not acquired ownership or the right of possession. The NHA had issued a clearance to dismantle structures, but its implementation was pending. The court found that the petitioners prematurely resorted to court action without exhausting available administrative remedies, which was contrary to established procedure. On the propriety of certiorari and the finality of judgments: The Court held that the petition for certiorari was not the proper remedy. The questioned orders of dismissal in Civil Case No. Q-32452 (dated June 13, 1981) and Civil Case No. Q-35920 (dated August 27, 1982) were appealable. Since the instant petition was filed on October 7, 1982, long after the reglementary periods for appeal had expired, the orders had become final and executory. The petitioners failed to show any circumstance justifying a deviation from the procedural rule of appeal or to explain why they did not observe the proper procedure. Resort to special civil actions like certiorari and mandamus is not allowed when a remedy by appeal exists and the period for appeal has already expired, as established in cases like Velasco Vda. de Caldito vs. Segundo and G.L. Enterprises, Inc. vs. Seneris. On the mootness of the issues: The Court found that the petition had become moot and academic. The houses and shanties of the petitioners, which were constructed on the property of Mabuhay Real Estate Investment & Financing Corporation, had already been demolished on October 8 and 9, 1982, as evidenced by the Accomplishment Report of the City Engineer of Quezon City. Consequently, the issues concerning the demolition orders and notices no longer presented an actual controversy that the Court could resolve.
Main Doctrine
A petition for certiorari will not prosper if the questioned orders have become final and executory, and the proper remedy of appeal was not availed of within the reglementary period, absent any justifiable reason for the deviation. Furthermore, issues that have become moot and academic due to supervening events, such as the demolition of the structures in question, will not be resolved.