Salva v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a forcible entry case initiated by petitioners, Rosalia P. Salva and her children, against respondent Governor Josephine R. Sato and relocated squatters. Petitioners claimed prior possession of a parcel of land within the National Food Authority (NFA) lot, which they had occupied for over thirty years, cultivating it and building structures. Governor Sato, in an effort to re-open the San Jose Airport, facilitated the relocation of squatters from the airport vicinity to a site on the NFA lot. Petitioners alleged that these relocated individuals, under the Governor's direction, forcibly entered and dispossessed them of their land. 2. Procedural History: The Municipal Trial Court (MTC) ruled in favor of the petitioners, finding them to be in actual possession and ordering the respondents to vacate and return possession. The Regional Trial Court (RTC), while affirming the MTC's decision regarding possession, excluded thirty-one defendants who were found not to have entered the disputed property. The respondent Governor then filed a Notice of Appeal with the Court of Appeals (CA), but this was dismissed for being an improper mode of appeal. Subsequently, the CA issued an entry of judgment, making the MTC decision final and executory. Despite this, Governor Sato filed a Petition for Certiorari and Prohibition with the CA, seeking to nullify the MTC's decision. The CA initially dismissed this petition, holding that certiorari could not substitute for a lost appeal. However, upon Governor Sato's Motion for Reconsideration, the CA reversed its earlier decision, granting certiorari and declaring the MTC and RTC decisions void. 3. The Petition: Petitioners filed a Petition for Review by Certiorari under Rule 45 of the Rules of Court, seeking to overturn the CA's Resolution that granted the Motion for Reconsideration and reversed its original decision. Petitioners argue that the CA gravely abused its discretion by allowing certiorari to substitute for a lost appeal, especially when the original judgment had become final and executory. They contend that the CA's finding that the relocated squatters occupied a different lot from the one claimed by petitioners was unsupported by evidence and that the RTC's ocular inspection had confirmed the parties' claims. Furthermore, petitioners assert that the CA erroneously branded them as squatters and that their prior possession was overwhelmingly proven by substantial evidence, including affidavits, photographs, and tax declarations. They also argue that the issue of jurisdiction was never raised by the respondent in lower courts and that she is estopped from questioning it at this late stage.
Issue(s)
Whether the Court of Appeals gravely abused its discretion in reversing its original decision and allowing a petition for certiorari to substitute for a lost appeal. Whether the Court of Appeals erred in assuming, without evidentiary support, that the relocation site was different from the land occupied by the petitioners; and whether the petitioners were in prior actual possession of the land, thereby establishing a case for forcible entry. Whether the respondent Governor Sato was estopped from questioning the jurisdiction of the courts after actively participating in the proceedings.
Ruling
The Supreme Court granted the petition, reversed and set aside the Resolution dated January 12, 1998 of the Court of Appeals, and reinstated its Decision dated October 22, 1996. The Court held that the Court of Appeals gravely abused its discretion in reversing its original decision and allowing a petition for certiorari to substitute for a lost appeal, especially when the judgment had become final and executory. The Court also found that the CA's assumption that the relocation site was different from the land occupied by petitioners was devoid of evidentiary support and that the petitioners had overwhelmingly proven their prior possession. Furthermore, the Court ruled that respondent Governor Sato was estopped from questioning the jurisdiction of the courts due to her active participation in the proceedings.
Ratio Decidendi
On the propriety of certiorari as a substitute for a lost appeal: The Court reiterated the settled rule that certiorari will not lie as a substitute for a lost appeal. It emphasized that a judgment that has become final and executory is immutable and unalterable. The Court found that the respondent Governor Sato failed to file a motion for reconsideration or elevate the dismissal of her appeal to the Supreme Court, allowing the period to lapse. Her subsequent petition for certiorari was therefore an improper attempt to revive a lost remedy. The Court cited Amigo v. Court of Appeals and Korean Airlines Co., Ltd. v. Court of Appeals to underscore that litigation must end and that parties should not be deprived of the fruits of a final verdict through schemes to prolong cases. The Court found no exceptional circumstances in this case to justify the exception to the rule, noting that respondent's reliance on the alleged negligence of her former counsel was insufficient to warrant a departure from the general rule, as she had actively participated in the proceedings and had the opportunity to change counsel. On the alleged difference in land lots and petitioners' prior possession: The Court found that the Court of Appeals' assumption that the relocation site (Lot 1626-C-2) was different from the land occupied by petitioners (Lot 1626-A-2) was unsubstantiated. The Court noted that respondent Governor Sato presented no evidence to support this claim, relying only on bare, unverified allegations in her motion for reconsideration. In contrast, the petitioners submitted overwhelming evidence, including affidavits, photographs, and realty tax declarations, proving their prior actual possession of the subject property. The Court highlighted that the Regional Trial Court, through an ocular inspection where all parties were represented, had categorically confirmed that the relocation site and the land occupied by petitioners were identical and that petitioners possessed the same at the time of the forcible entry. The Court reiterated that in ejectment cases, the issue is actual prior possession, and a party with prior possession can recover it even against the owner. On the issue of jurisdiction and estoppel: The Court found no basis for the respondent Court of Appeals' conclusion that the Municipal Trial Court and Regional Trial Court decisions were void for want of jurisdiction. The Court stated that jurisdiction is conferred by law based on the allegations in the complaint, and the petitioners' complaint for forcible entry clearly fell within the MTC's exclusive jurisdiction. Crucially, the Court noted that respondent Governor Sato never raised the issue of jurisdiction in her pleadings before the MTC, RTC, or CA, nor did she elevate the dismissal of her appeal to the Supreme Court on this ground. By actively participating in the proceedings and invoking the jurisdiction of these courts, she was deemed to have submitted herself to their authority. The Court applied the doctrine of estoppel and laches, citing the landmark case of Tijam v. Sibonghanoy, which prohibits parties from assailing a court's jurisdiction after actively participating in the proceedings and accepting favorable judgments, or after the judgment has become final and executory. The Court condemned the "undesirable practice" of parties trifling with the courts by taking inconsistent positions.
Main Doctrine
A petition for certiorari cannot be used as a substitute for a lost appeal, especially when the judgment sought to be annulled has long become final and executory, unless exceptional circumstances warranting such recourse are clearly established. Furthermore, a party who actively participates in proceedings and invokes the jurisdiction of a court cannot later assail that same jurisdiction, particularly after the judgment has become final.