Professional Regulation Commission v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents, graduates of Fatima College of Medicine, took the physicians' licensure examinations in February 1993. They alleged that petitioners (PRC, Chairman Pobre, and Commissioner Pascual) arbitrarily refused to administer their oaths and withheld their licenses despite passing the examinations, singling them out for high ratings in specific subjects. They filed a petition for mandamus with the RTC-Manila. Procedural History: The RTC-Manila granted a preliminary mandatory injunction ordering petitioners to administer the oaths and register the private respondents. The Court of Appeals nullified this injunction, opining that petitioners' functions were discretionary, not ministerial. This ruling was affirmed by the Supreme Court upon review. Meanwhile, the RTC-Manila declared petitioners to have waived their right to cross-examine witnesses. Petitioners' subsequent motions were denied by the RTC-Manila. The Board of Medicine charged the examinees with immorality and dishonest conduct. The RTC-Manila granted a restraining order against the administrative case. Petitioners sought nullification of the RTC orders before the Court of Appeals, which declared the orders void and ordered the RTC to allow cross-examination and presentation of evidence. Petitioners' motion for reconsideration, seeking dismissal of the mandamus case, was denied. The RTC-Manila subsequently rendered judgment on the merits, ordering petitioners to allow the oaths and registration, without prejudice to administrative actions. Petitioners filed a notice of appeal. They also secured a temporary restraining order from the Supreme Court enjoining execution pending appeal. The Petition: Petitioners filed two consolidated petitions. G.R. No. 117817 assailed the Court of Appeals' decision for not ordering the dismissal of the mandamus case. G.R. No. 118437 sought the nullification of the RTC judge's order denying their motion for inhibition and his decision granting mandamus, alleging grave abuse of discretion and partiality. Petitioners also sought the dismissal of the mandamus case. The Supreme Court consolidated these petitions.
Issue(s)
Whether the petition in G.R. No. 117817 has become moot due to the trial court rendering a decision on the merits and petitioners filing a notice of appeal. Whether the petition in G.R. No. 118437 constitutes forum shopping. Whether the remedies of appeal and certiorari are mutually exclusive. Whether the RTC judge committed grave abuse of discretion in denying the motion for inhibition.
Ruling
The petition in G.R. No. 117817 is dismissed for being moot. The petition in G.R. No. 118437 is dismissed on the ground that there is a pending appeal before the Court of Appeals. Assistant Solicitor General Amparo M. Cabotaje-Tang is advised to be more circumspect in her dealings with the courts.
Ratio Decidendi
On the mootness of G.R. No. 117817: The issue of whether the Court of Appeals erred in not ordering the dismissal of the mandamus case has been rendered moot by the trial court's decision on the merits. This decision, rendered after the petition was filed, granted the writ of mandamus. Petitioners subsequently filed a notice of appeal, making the remedy of appeal available and rendering the petition for certiorari before the Supreme Court unnecessary and without practical use or value. The Court reiterated that a case becomes moot when its resolution would have no practical effect. On forum shopping in G.R. No. 118437: The Court held that forum shopping was not established. For forum shopping to exist, both actions must involve the same transactions, essential facts, and circumstances, with identical causes of action, subject matter, and issues. While an appeal was pending before the Court of Appeals concerning the same transactions and subject matter, the issues raised in the petition for certiorari were alleged to be different and were not substantiated by respondents. The mere pendency of an appeal does not automatically constitute forum shopping. On the mutual exclusivity of appeal and certiorari: The Court reiterated the settled rule that the remedies of ordinary appeal and certiorari are mutually exclusive. While exceptions exist, such as when the appeal is not a plain, speedy, and adequate remedy, this exception was not found applicable here. The Court noted that petitioners had a pending appeal before the Court of Appeals, which could adequately grant the relief they sought. Allowing both remedies simultaneously would lead to absurdity and confusion, as two courts would be reviewing the same decision. On the RTC judge's denial of inhibition: The Court found that the petition for certiorari seeking to nullify the denial of the motion for inhibition was improper because a plain, speedy, and adequate remedy by way of appeal was available. The alleged grave abuse of discretion in denying the inhibition could be assigned as an error in the appeal. The Court emphasized that certiorari is not a substitute for appeal, especially when the latter can provide adequate relief. The conduct of filing the petition for certiorari despite a pending appeal was deemed to border on the censurable.
Main Doctrine
A petition for certiorari is generally not available when a party has a pending appeal, as the remedies are mutually exclusive. However, exceptions exist where the appeal is not a plain, speedy, and adequate remedy. Furthermore, a case may be rendered moot by subsequent events, such as a trial court rendering a decision on the merits after a petition for certiorari was filed challenging earlier procedural orders.