Raymundo v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from a complaint filed by Juan Marcos Arellano, Jr. against Nilo H. Raymundo for the collection of a sum of money amounting to P3,625,000.00, plus interest, moral damages, exemplary damages, attorney's fees, and costs. Raymundo filed an answer with counterclaim, and subsequently sought to amend his answer. The trial court, however, struck out Raymundo's amended answer and manifestation. 2. Procedural History: Following the striking of his amended answer, Raymundo failed to attend a pre-trial conference, leading the Regional Trial Court (RTC) to declare him in default and allow the plaintiff to present evidence ex-parte. Raymundo's subsequent motions to set aside the default order and the ex-parte evidence were not resolved by the RTC. Despite these pending motions, the RTC rendered a decision in favor of the plaintiff. Raymundo's motion for reconsideration and petition for relief from judgment were denied. He then filed a notice of appeal to the Court of Appeals. Subsequently, he filed a special civil action for certiorari with the Court of Appeals, challenging the RTC's proceedings. 3. The Petition: The Court of Appeals dismissed Raymundo's petition for certiorari, ruling that certiorari is not available when an appeal is a plain, speedy, and adequate remedy, and that the trial court's failure to resolve the motions constituted errors in proceedings, not grave abuse of discretion. Raymundo filed a petition for review on certiorari with the Supreme Court, arguing that certiorari was appropriate due to the trial court's grave abuse of discretion in declaring him in default and proceeding ex-parte without resolving his pending motions, rendering the remedy of appeal inadequate.
Issue(s)
Whether the Court of Appeals erred in denying the issuance of a writ of certiorari solely on the ground of the availability of appeal. Whether the trial court committed grave abuse of discretion amounting to lack or excess of jurisdiction in declaring petitioner in default and in allowing the presentation of respondent's evidence ex-parte without resolving petitioner's pending motions.
Ruling
The petition is granted. The Resolution of the Court of Appeals is reversed and set aside. The trial court's decision dated September 3, 1997, and order dated May 12, 1998, are set aside. The case is remanded to the trial court for further proceedings.
Ratio Decidendi
On whether the Court of Appeals erred in denying the issuance of a writ of certiorari solely on the ground of the availability of appeal: The Court held that while an ordinary appeal is the proper remedy for a judgment by default and an order denying a petition for relief, certiorari may lie in exceptional circumstances where appeal is inadequate. The Court emphasized that certiorari is available to correct despotic exercises of discretion, especially when the lower court's actions amount to grave abuse of discretion or lack or excess of jurisdiction. The availability of appeal does not automatically preclude certiorari if the appeal is not an adequate, equally beneficial, speedy, and sufficient remedy. On whether the trial court committed grave abuse of discretion amounting to lack or excess of jurisdiction: The Court found that the trial court gravely abused its discretion in declaring petitioner in default and in allowing the presentation of respondent's evidence ex-parte without resolving petitioner's pending motions. The failure to act on the motions to set aside the default order and the ex-parte evidence was not a mere oversight but seriously affected the trial court's discretion, depriving petitioner of the opportunity to be heard. The Court noted that petitioner's non-attendance at the pre-trial was predicated on the unresolved motion to admit his amended answer, which should have taken precedence. The trial court's actions were characterized as despotic, capricious, arbitrary, and whimsical, amounting to grave abuse of discretion.
Main Doctrine
Certiorari may lie even if an appeal is available, where the appeal is not adequate, or equally beneficial, speedy, and sufficient, particularly when the lower court's orders were issued with grave abuse of discretion amounting to lack or excess of jurisdiction.