Enriquez v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Felicitas Enriquez and private respondents, spouses Reynaldo and Natividad Santos, were long-time occupants of neighboring lots on Laon Laan Street, Caloocan City. These lots were part of a larger tract owned by spouses Justo de Dios and Basilia Manotoc. In 1976, the private respondents purchased a 200-square meter portion of this land, which was later discovered to encompass the 90-square meter area occupied by petitioner's house. Consequently, petitioner began paying rent to the private respondents. Procedural History: The dispute escalated when private respondents filed an ejectment suit in 1982, leading to a Metropolitan Trial Court order for petitioner to vacate. This decision was affirmed by the Regional Trial Court (RTC) on appeal. Subsequently, petitioner filed several actions, including one for annulment of the sale and damages, which was dismissed. However, in a separate case (Civil Case No. C-10837), the RTC ordered the private respondents to sell the 90-square meter portion occupied by petitioner's house to her at P100 per square meter, along with damages. The private respondents appealed this decision to the Court of Appeals (CA), which initially dismissed the appeal but later reinstated it. On August 27, 1987, the CA reversed the RTC's decision, setting aside the order for the sale and damages. The Petition: Petitioner Felicitas Enriquez filed a special civil action for certiorari under Rule 65 of the Rules of Court, assailing the August 27, 1987 decision of the Court of Appeals. She argued that certiorari was the appropriate remedy because her right to appeal had been lost or had become impossible. Petitioner contended that the CA committed reversible error in setting aside the trial court's decision. The Supreme Court, however, found the petition without merit, noting that the CA's decision had become final and executory and that certiorari cannot substitute for a lost appeal except in exceptional circumstances not present in this case.
Issue(s)
Whether the Supreme Court can review a decision of the Court of Appeals that has become final and executory. Whether a special civil action for certiorari under Rule 65 can be used to substitute for a lost appeal.
Ruling
The petition is DISMISSED. The assailed decision of the Court of Appeals, having become final and executory, is upheld.
Ratio Decidendi
On the issue of reviewing a final and executory decision: The Court reiterated the settled rule that once a judgment has become final, the issues therein should be laid to rest. The records clearly show that the Court of Appeals' decision dated August 27, 1987, became final and executory on February 3, 1988, as indicated by the Entry of Judgment. Therefore, this Court will not disturb a judgment that has attained finality, as it becomes the law of the case, irrespective of any alleged error. On the issue of certiorari as a substitute for a lost appeal: The Court found petitioner's contention that certiorari is proper because the remedy of appeal was lost to be devoid of merit. The Court emphasized that certiorari under Rule 65 cannot take the place of a lost appeal, except in specific exceptional circumstances where the appeal would be inadequate, slow, insufficient, and would not promptly relieve a party from the injurious effects of the judgment. The records of the present case do not demonstrate that petitioner's situation falls within any of these exceptional instances. Thus, the petition for certiorari was dismissed.
Main Doctrine
A special civil action for certiorari under Rule 65 cannot take the place of a lost appeal, except in specific instances where the appeal would be inadequate, slow, insufficient, and would not promptly relieve a party from the injurious effects of the judgment complained of. Once a judgment becomes final and executory, it becomes the law of the case and cannot be annulled by a special civil action of certiorari.