Barangay Blue Ridge "A" of Quezon City v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Petitioners, residents and homeowners of Barangay Blue Ridge "A" in Quezon City, filed a complaint for injunction and damages against Pilipinas Shell Petroleum Corporation. They alleged that the construction of a gasoline filling service station by the private respondent within their residential subdivision violated certain barangay ordinances and resolutions. 2. Procedural History: The Regional Trial Court of Quezon City dismissed the petitioners' complaint for failure to state a cause of action and subsequently denied their motion for reconsideration. Aggrieved, the petitioners filed a petition for certiorari with the Court of Appeals, alleging grave abuse of discretion by the trial court judge. The Court of Appeals denied this petition, ruling that the proper remedy was an appeal under Rule 41, not a special civil action for certiorari under Rule 65. The denial was further solidified when the Court of Appeals denied the petitioners' motion for reconsideration. 3. The Petition: The petitioners have appealed to the Supreme Court under Rule 45 of the Revised Rules of Court, seeking to overturn the Court of Appeals' resolutions. The core of their argument is that the Court of Appeals erred in denying their petition for certiorari. The Supreme Court is tasked with determining whether the Court of Appeals correctly concluded that certiorari was not the appropriate remedy, given that an appeal under Rule 41 was available and that any alleged errors by the trial court constituted errors of judgment, not of jurisdiction.
Issue(s)
Whether the Court of Appeals erred in denying the petition for certiorari. Whether the RTC committed grave abuse of discretion in dismissing the complaint.
Ruling
The petition is DENIED and the resolutions of the Court of Appeals dated July 26, 1993 and September 13, 1993 are AFFIRMED.
Ratio Decidendi
On Whether the Court of Appeals erred in denying the petition for certiorari: The Court held that a basic requisite for a special civil action of certiorari to lie is the absence of any appeal, or plain, speedy, and adequate remedy in the ordinary course of law. Certiorari is a remedy of last resort, intended to keep inferior tribunals within their jurisdiction, and cannot be used as a substitute for a lost appeal. It is not meant to correct errors of procedure or mistakes in a judge's findings or conclusions. In this case, the CA correctly identified that an ordinary appeal under Rule 41 was the proper remedy, not a petition for certiorari under Rule 65. On Whether the RTC committed grave abuse of discretion in dismissing the complaint: The Court found that the RTC did not commit grave abuse of discretion. The RTC meticulously enumerated and discussed the elements of a cause of action in its resolution dismissing the complaint. It specifically addressed the legal right of the plaintiffs and the exception provided by MMA Ordinance No. 81-01 concerning the private respondent's construction. The RTC's determination that the elements of a cause of action were not established, based on its interpretation of the ordinance and the facts, constituted an error of judgment, not an error of jurisdiction. Grave abuse of discretion implies an arbitrary or despotic exercise of power, which was not demonstrated here. Any error committed by the RTC was an error of judgment, which should be reviewed by ordinary appeal.
Main Doctrine
A special civil action for certiorari is a remedy of last resort and cannot be used as a substitute for a lost appeal or to correct errors of judgment, not errors of jurisdiction.