Casis v. Court of Appeals
REITERATIONFacts
The Antecedents: The case involves a house and lot originally titled in the name of Nenita Suroza. Suroza sold the property twice: first to Cielito T. Santos on June 30, 1983, and second to Roderick M. Casis on July 19, 1983. Santos had been given the owner's copy of the title by Suroza on February 10, 1983, after paying the mortgage redemption amount. A deed of sale in favor of Santos was executed on June 23, 1983, and he took possession and began renovations. Suroza filed a petition for reconstitution of title on May 17, 1983, claiming the original was lost. After obtaining a reconstituted title, she sold the property to Casis, who registered the sale and obtained a new title. Procedural History: Roderick M. Casis filed an Ejectment case against Cielito T. Santos with the Metropolitan Trial Court (MTC). The MTC issued a Temporary Restraining Order (TRO), which was later dissolved on September 26, 1983. Casis's motion for reconsideration was denied. Casis filed a petition for certiorari and prohibition with the Regional Trial Court (RTC), which was dismissed. His motion for reconsideration was also denied. Casis appealed to the Court of Appeals (CA), which dismissed his petition for lack of merit. Separately, Casis filed a Quieting of Title case with the RTC, seeking a preliminary mandatory injunction, which was denied. His petition for certiorari with the CA questioning this denial was dismissed. Casis then filed a petition for certiorari with the Supreme Court (SC) in G.R. No. 75248, which was denied and became final. The CA, in the ejectment case, also dismissed Casis's appeal for lack of merit. The Petition: Casis filed a petition for certiorari with the Supreme Court, assailing the CA's decision in the ejectment case, alleging grave abuse of discretion and error in not awarding possession to him. He raised issues concerning the propriety of certiorari, the similarity of the cases as a bar, and the validity of the MTC order.
Issue(s)
WHETHER OR NOT CERTIORARI IS THE PROPER REMEDY OF PETITIONER. WHETHER OR NOT G.R. NO. 75248 WHICH ORIGINATED FROM THE QUIETING OF TITLE CASE IS SIMILAR HENCE A BAR TO THE PRESENT PETITION. WHETHER OR NOT THE QUESTIONED ORDER OF THE METROPOLITAN TRIAL COURT OF PARANAQUE, DATED SEPTEMBER 26, 1983, IS CONTRARY TO EXISTING LAWS AND JURISPRUDENCE AND EVIDENCE ON RECORD AND IF THE SAME WAS ISSUED IN GREAT ABUSE OF DISCRETION AMOUNTING TO LACK OR EXCESS OF JURISDICTION.
Ruling
The Supreme Court denied the petition for lack of merit. The Court found no reversible error in the assailed orders of the Court of Appeals.
Ratio Decidendi
On the issue of whether certiorari is the proper remedy: The Court held that certiorari is not the proper remedy to correct errors in the findings and conclusions of a judge from proven facts. The petitioner's arguments primarily dealt with the admission or non-admission of evidence and the factual conclusions drawn therefrom. The Court reiterated the well-settled doctrine that only questions of law, not those involving the examination of the probative value of evidence, are subject to review by the Supreme Court. The Court is bound by the factual findings of the lower courts unless they are based on surmises and conjectures. The petitioner failed to prove grave abuse of discretion or a jurisdictional defect. On the issue of whether G.R. No. 75248 is a bar to the present petition: The Court found merit in the appellate court's finding that there was hardly any appreciable difference between the forcible entry case and the quieting of title case. Both cases involved the issue of possession pending determination of ownership, and the petitioner's prayer in both was essentially to be given possession of the property. The Court noted that at the time the CA rendered its decision in the forcible entry case, the SC had not yet made a pronouncement in the quieting of title case (G.R. No. 75248). The CA dismissed the appeal in the forcible entry case in deference to the SC's eventual decision. Since G.R. No. 75248 became final and executory, sustaining the denial of petitioner's prayer for preliminary injunction, this further supported the dismissal of the present petition. On the issue of the validity of the MTC order and grave abuse of discretion: The Court found that the main issue before the MTC was who had the better right to possess the property pending the resolution of ownership. The MTC's order dissolving the TRO was based on its evaluation of the evidence, which led it to conclude that defendant Santos had a better right to possession. The Court noted that the petitioner's insistence that the MTC relied on hearsay evidence merely strengthened the view that the issue was one of appreciation of evidence, which is a factual matter not reviewable by certiorari. The Court found that the MTC properly considered the sale to Santos on June 23, 1983, and the transfer of possession, even with Suroza's continued stay by tolerance. The Court also highlighted that Suroza had already lost her right or interest by reason of the sale to Santos and her prior certification acknowledging Santos's mother as vendee. The subsequent sale to Casis, despite registration, did not vest him with a better right of possession because Suroza no longer had the right to sell the property. The Court also pointed out irregularities in Suroza's actions, such as filing for reconstitution of title when she had already delivered the duplicate title to the mortgagees.
Main Doctrine
Certiorari is not the proper remedy to correct errors in the findings and conclusions of a judge from proven facts, especially when the issue revolves around the appreciation or misappreciation of evidence. The Court is bound by the factual findings of lower courts unless they are based on surmises and conjectures.