Filipino Merchants' Insurance Co., Inc. v. Intermediate Appellate Court
REITERATIONFacts
1. The Antecedents: The underlying dispute arose from a vehicular accident in April 1978 that resulted in the death of the private respondents' son. The spouses Alfredo and Demetria Calaquian filed a complaint for damages against several parties, including the petitioner, Filipino Merchants' Insurance Co., Inc., which was the insurer of one of the parties involved. 2. Procedural History: The trial court, on April 26, 1984, found the petitioner jointly and severally liable with other defendants for P30,000.00 in damages to the Calaquians. No appeal was filed by the petitioner. Subsequently, the Calaquians moved for and were granted a writ of execution. On January 28, 1985, the sheriff levied on the petitioner's typewriters for auction. One day before the scheduled auction, the petitioner filed a petition for relief from judgment and an application for a preliminary injunction. On February 9, 1985, the petitioner filed a petition for mandamus with the Intermediate Appellate Court (IAC) against the trial judge for inaction. The IAC dismissed the petition for mandamus on June 20, 1985, and denied a motion for reconsideration on July 25, 1985. 3. The Petition: This case is a petition for review on certiorari filed by Filipino Merchants' Insurance Co., Inc. with the Supreme Court, challenging the IAC's decision. The petitioner argues that the IAC erred in not applying the ruling in Vda. de Sayman vs. Court of Appeals to enjoin the execution and auction sale. The petitioner also contends that its petition for relief from judgment was prematurely dismissed and that the mandamus petition was improperly handled. The Supreme Court, however, found the petition for mandamus premature and the issue of enjoining execution moot, as the petitioner had already satisfied the judgment against it by paying P30,000.00 under protest.
Issue(s)
Whether the respondent court committed reversible error in dismissing the petition. Whether the petition for mandamus was premature. Whether the issue of enjoining the execution became moot and academic. Whether the respondent court erred in refusing to convert the petition for mandamus into a petition for certiorari.
Ruling
The Supreme Court affirmed the decision of the Intermediate Appellate Court, finding no reversible error and denying the petition for lack of merit.
Ratio Decidendi
On the issue of reversible error: The Supreme Court ruled that the respondent court did not commit reversible error. The Court found that the petition for mandamus was manifestly premature as it was filed only four days after the petition for relief from judgment, and the trial court judge could scarcely be expected to act on it within that timeframe, considering docket load and time constraints. The Court also noted that the trial court had already acted on the petition for relief by issuing an order directing the private respondents to comment, thereby rendering the mandamus petition moot and academic. On the issue of prematurity of mandamus: The Court held that the petition for mandamus was indeed premature. It emphasized that while prompt action is desirable, time constraints and the court's docket must be considered. The filing of the petition for mandamus barely four days after the petition for relief from judgment was too soon to expect a definitive action from the trial court. On the issue of mootness: The Supreme Court agreed with the respondent court that the issue of enjoining the execution had become moot and academic. This was because the petitioner had paid the P30,000.00 liability adjudged against it, albeit under protest. The Court reasoned that once the liability adjudged in the decision has been satisfied, there is no longer any reason to enjoin or suspend the execution, rendering the case moot. On the issue of conversion to certiorari: The Court found that the respondent court acted correctly in dismissing the petition, even if considered as one for certiorari. The supervening circumstances, particularly the payment of the judgment amount, introduced factual matters that raised the issue of mootness. Questions of fact are improper in a special civil action for certiorari and are best left for trial on the merits.
Main Doctrine
A petition for mandamus to compel a trial court to act on a petition for relief from judgment is premature if filed only four days after the petition for relief, considering the court's docket load. Furthermore, issues become moot and academic when the liability adjudged in the decision has been satisfied, even if paid under protest.