Roadway Express, Inc. v. Court of Appeals
REITERATIONFacts
1. The Antecedents: A vehicular accident occurred involving a freight truck registered to petitioner Roadway Express, Inc. and a Lancer car owned and driven by private respondent Edilberto C. Perez. This incident led to a complaint for damages filed by petitioners against respondent Perez before the Municipal Trial Court (MTC). 2. Procedural History: The MTC dismissed both the petitioners' complaint and respondent Perez's counterclaim. Both parties appealed to the Regional Trial Court (RTC), which affirmed the dismissal of the complaint but reversed the dismissal of the counterclaim. Petitioners then filed a petition for review with the Court of Appeals (CA). The CA summarily dismissed this petition due to the absence of the trial court's docket number in the caption and the lack of a certification concerning forum shopping. Petitioners' motion for reconsideration was subsequently denied. 3. The Petition: Petitioners seek a writ of certiorari from the Supreme Court, alleging grave abuse of discretion by the CA in dismissing their petition for review. They argue that their petition substantially complied with Circular 28-91 regarding the docket number and that their ex-parte manifestation served as a certification of non-forum shopping. They also challenge the MTC and RTC decisions, but the Court finds that certiorari is not the proper remedy for alleged errors of judgment and that the petition was filed beyond the reasonable period.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in dismissing the petition for review for alleged non-compliance with Circular 28-91. Whether the MTC and RTC committed grave abuse of discretion in holding petitioners liable to private respondent.
Ruling
The petition is GRANTED. The May 30, 1995 and August 14, 1995 resolutions of the Court of Appeals are SET ASIDE. The records of this case are REMANDED to the Court of Appeals for proper disposition.
Ratio Decidendi
On the alleged grave abuse of discretion by the CA: The Court found that the CA committed grave abuse of discretion. Circular 28-91 requires the docket number of the lower court case in the caption of the petition and a certification of non-forum shopping. While the docket numbers were not in the caption, they were present in the body of the petition and in the attached decisions, constituting substantial compliance. Furthermore, the petitioners had filed an ex-parte manifestation containing the requirements of a certification of non-forum shopping prior to the CA's dismissal. The Court also noted that the petition was filed after the revision of Circular 28-91 on April 1, 1994, which deleted the requirement for the docket number to be in the caption. On the alleged grave abuse of discretion by the MTC and RTC: The Court ruled that this issue was not meritorious. Firstly, a petition for certiorari under Rule 65 is only available when there is no plain, speedy, and adequate remedy in the ordinary course of law, and appeal was available and availed of by the petitioners. Secondly, the petition for certiorari was filed beyond the reasonable period of three months from receipt of the lower courts' decisions. Finally, certiorari under Rule 65 is only for correcting errors of jurisdiction, not errors of judgment, and the finding of negligence by the lower courts did not involve a question of jurisdiction.
Main Doctrine
The Court of Appeals committed grave abuse of discretion in summarily dismissing a petition for review for non-compliance with Circular 28-91, where substantial compliance was evident or where the petition was filed after the revision of the Circular deleted the contested requirement. Furthermore, a petition for certiorari under Rule 65 is not the proper remedy when an appeal is available, and it must be filed within a reasonable period, typically three months.