Tuazon v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Aida Tuazon was the defendant in an ejectment case decided adversely against her by the Metropolitan Trial Court of Manila. The Regional Trial Court, Branch 16, Manila, affirmed the decision on appeal. Petitioner's motion for reconsideration was denied. Procedural History: Petitioner filed a petition for certiorari under Rule 65 of the Revised Rules of Court with the Court of Appeals (CA-G. R. SP No. 30005). The Court of Appeals dismissed the petition, holding that the proper mode of appeal from the Regional Trial Court's decision in its appellate capacity should have been a petition for review under Circular No. 2-90. Petitioner's motion for reconsideration, which included a motion to amend the title to "Petition for Review," was denied. The Petition: The present petition seeks to reverse the resolutions of the Court of Appeals.
Issue(s)
Whether the petition filed under Rule 65 can be treated as a petition for review under Section 22 of the Judiciary Reorganization Act of 1980, Section 22 (b) of the Interim Rules, and Circular No. 2-90. Whether the Court of Appeals erred in dismissing the petition for certiorari without passing on the merits of the case.
Ruling
The petition is GRANTED. The Resolutions of the Court of Appeals are REVERSED, and the Court of Appeals is ORDERED to decide the appealed case in CA-G. R. No. SP No. 30005 on the merits.
Ratio Decidendi
On the issue of treating the petition as a petition for review: The Court held that there is no question that the decision of the Regional Trial Court subject of the petition for certiorari was rendered in the exercise of its appellate jurisdiction. Under Section 22 of the Judiciary Reorganization Act of 1980 and Section 22 (b) of the Interim Rules, decisions of the Regional Trial Court in cases appealed from the Metropolitan Trial Court shall be appealed by petition for review to the Court of Appeals. The Court agreed with the petitioner that her petition filed with the Court of Appeals could be treated as a petition for review under Circular No. 2-90, even without changing the designation of the pleading from "Petition" to "Petition for Review." The form and substance of the petition filed in the Court of Appeals satisfied all the requirements of a petition for review under the cited provisions. It contained a statement of the nature of the action, a summary of the proceedings, pertinent facts, grounds relied upon, and the duplicate of the Regional Trial Court's decision. It also discussed assigned errors under the heading "Argument" with citations of authorities and specified the judgment sought. The Court considered the statement in the petition invoking Rule 65 as surplusage that could not detract from its consideration as a petition for review. On the Court of Appeals' dismissal: The Court found that the Court of Appeals erred in dismissing the petition for certiorari solely on the ground of improper mode of appeal. While the proper mode of appeal from a Regional Trial Court's decision in its appellate capacity is a petition for review, the Court has consistently held that a petition for certiorari may be treated as a petition for review if it sufficiently alleges and establishes the grounds for review and meets the requirements thereof. The petition filed by the petitioner contained the necessary elements of a petition for review, thus warranting a decision on the merits by the Court of Appeals. The dismissal of the petition without considering the substantive issues constituted a grave abuse of discretion amounting to lack of jurisdiction.
Main Doctrine
A petition filed under Rule 65 of the Revised Rules of Court, which assails a decision of the Regional Trial Court rendered in its appellate jurisdiction, may be treated as a petition for review under Circular No. 2-90, provided it meets the requirements for such a petition, even if not explicitly designated as such.