Dela Cruz v. Intermediate Appellate Court
REITERATIONFacts
1. The Antecedents: The underlying dispute involves petitioners Serafin Dela Cruz, Eladio Macenas, and Rodrigo Diaz filing a complaint for the annulment of Transfer Certificate of Title (TCT) Nos. 274534, 274535, 274537, and 274539, along with a claim for damages. This complaint was lodged in the Court of First Instance of Rizal, Quezon City, Branch XVI, and was assigned to Judge Antonio P. Solano. 2. Procedural History: After the complaint was filed and summons served, the private respondents filed a Motion to Dismiss, asserting lack of jurisdiction. Judge Solano initially denied this motion. However, upon a Motion for Reconsideration by the private respondents, the judge reversed his earlier order and dismissed the petitioners' complaint. A subsequent Motion for Reconsideration filed by the petitioners was also denied. Aggrieved, the petitioners filed a petition for certiorari, prohibition, and mandamus with the Intermediate Appellate Court (IAC), which subsequently dismissed their petition. 3. The Petition: The petitioners are now before the Supreme Court via a petition for certiorari, arguing that the respondent judge abused his discretion in issuing the orders dismissing their complaint and denying their motion for reconsideration. They also contend that the respondent appellate court abused its discretion amounting to lack of jurisdiction by dismissing their petition without requiring comments from the respondents. The petitioners seek to have the orders of dismissal and the IAC's decision set aside and to have their original complaint heard.
Issue(s)
Whether the respondent Intermediate Appellate Court committed a grave abuse of discretion amounting to lack of jurisdiction in dismissing the petition for certiorari, prohibition, and mandamus, arguing it was a substitute for a lost appeal. Whether the respondent judge committed a grave abuse of discretion in issuing the orders dated October 20, 1982, and January 14, 1983, dismissing the petitioners' complaint, specifically regarding the court's jurisdiction over the subject matter.
Ruling
The petition is denied. The Supreme Court affirmed the decision of the Intermediate Appellate Court, holding that the petition for certiorari was without merit.
Ratio Decidendi
On the Issue of Certiorari as a Substitute for a Lost Appeal: The Supreme Court held that the petition for certiorari filed before it was without merit. Time and again, the Court has dismissed petitions for certiorari aimed at annulling decisions or orders that could have been appealed but were not. When a court has jurisdiction over the subject matter, as the respondent judge had in this case, all orders and decisions pertaining to the cause are within its jurisdiction. Even if erroneous, such orders cannot be corrected by certiorari. This special civil action does not lie where the remedy by appeal has been lost, as certiorari cannot take the place of an appeal. The petitioners' proper remedy was to appeal the order of dismissal, not to file a petition for certiorari, prohibition, and mandamus. On the Alleged Grave Abuse of Discretion by the Respondent Judge: The Court found no grave abuse of discretion on the part of the respondent judge. The core issue presented by the private respondents' motion to dismiss was the jurisdiction of the court over the subject matter of the complaint for annulment of titles. While the judge initially denied the motion to dismiss, he later reconsidered and granted it. The Supreme Court's focus was not on whether the judge's final decision on jurisdiction was correct, but on whether the judge acted with grave abuse of discretion amounting to lack of jurisdiction in issuing the orders. Since the judge had jurisdiction over the case, his orders, even if potentially erroneous, were within his jurisdiction and could not be assailed via certiorari. The respondents correctly pointed out that the petitioners' remedy was an appeal from the order of dismissal.
Main Doctrine
The Supreme Court reiterated that a petition for certiorari under Rule 65 of the Rules of Court is an extraordinary remedy that lies only when a tribunal, board, or officer exercising judicial, quasi-judicial, or ministerial functions has acted without or in excess of its jurisdiction, or with grave abuse of discretion amounting to lack of jurisdiction. It is not a substitute for a lost appeal, and it cannot be used to correct errors of law or fact committed by a lower court acting within its jurisdiction. The availability of an appeal is a plain, speedy, and adequate remedy that bars the grant of certiorari.