Asian Trading Corporation v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Philippine Banking Corporation (Bank) filed a collection suit against Asian Trading Corporation, Miguel L. Romero, and Edcel C. Lagman for P2,700,000.00 plus interest and attorney's fees. The action was based on a promissory note executed on July 9, 1982, with a due date of August 9, 1984. The note included an acceleration clause allowing the Bank to demand the entire principal upon default of any installment or other obligations. The Bank alleged that the petitioners defaulted on the first two semi-annual installments due January 9, 1983, and July 9, 1983, making the entire amount due and demandable. 2. Procedural History: The petitioners, in their answer, claimed the obligation was not yet due, as payments were agreed to commence only after the due date of August 9, 1984. After the Bank presented its evidence, the petitioners filed a demurrer to evidence, which the trial court denied. The trial court then rendered judgment in favor of the Bank. Petitioners elevated the matter to the Court of Appeals via a petition for certiorari and prohibition, arguing they were denied due process by not being allowed to present evidence. The Court of Appeals dismissed the petition, finding the genuineness and due execution of the note admitted, non-payment admitted, and the only defense relying on the note itself, which was already before the court. The appellate court reasoned that further presentation of evidence would be a futile formality. Petitioners then filed the present petition for review on certiorari with the Supreme Court. 3. The Petition: The petitioners seek reversal of the Court of Appeals' decision through a petition for review on certiorari. They contend that the appellate court erred in holding that certiorari was the proper remedy instead of appeal, given the trial court's denial of their right to present evidence. They also argue that the appellate court demeaned their right to present evidence, considering it an empty formality and an exercise in futility. The Supreme Court, in its resolution, noted that despite settlement negotiations, the parties failed to agree, and the dispute over attorney's fees among the parties and their former lawyers was to be adjudicated in the main petition. The Court ultimately denied the petition, finding that certiorari was unavailable as an appeal was the proper remedy and that the appellate court did not commit grave abuse of discretion.
Issue(s)
Whether the Court of Appeals erred in holding that appeal, and not certiorari, was the proper remedy for the petitioners. Whether the Court of Appeals erred in considering the petitioners' right to present evidence as an empty formality and an exercise in futility, thereby allegedly depriving them of due process.
Ruling
The petition is denied for want of merit. The Supreme Court affirmed the decision of the Court of Appeals.
Ratio Decidendi
On the propriety of certiorari: The Supreme Court reiterated the well-entrenched doctrine that a special civil action for certiorari under Rule 65 of the Rules of Court lies only when there is no appeal, or any plain, speedy, and adequate remedy in the ordinary course of law. The Court emphasized that certiorari cannot be allowed when a party fails to appeal a judgment despite the availability of that remedy. In this case, the petitioners had the remedy of appeal from the denial of their demurrer to evidence, but they instead resorted to a petition for certiorari. Furthermore, the Court noted that a motion for reconsideration is generally an adequate remedy, and its absence before filing a petition for certiorari would ordinarily cause the petition to fail, unless exceptional circumstances exist. The Court found that the petitioners' resort to certiorari was improper given the availability of appeal. On the alleged deprivation of due process and the right to present evidence: The Supreme Court agreed with the Court of Appeals that considering the petitioners' desire to present evidence as an empty formality and an exercise in futility was not an error. The Court explained that the sole office of the writ of certiorari is the correction of errors of jurisdiction, including grave abuse of discretion amounting to lack or excess of jurisdiction, and not to correct errors of judgment or procedure. The Court found that the respondent court did not commit grave abuse of discretion in its assessment. The genuineness and due execution of the promissory note were admitted, and the core of the defense rested on the interpretation of the due date, which was evident from the face of the document itself. Therefore, requiring the presentation of further evidence on this point would indeed be a useless formality, as the evidence was already before the court for its consideration.
Main Doctrine
A petition for certiorari under Rule 65 is not a substitute for an appeal, and it will not prosper if the aggrieved party has a plain, speedy, and adequate remedy in the ordinary course of law, such as an appeal. Furthermore, a motion for reconsideration must generally be filed before resorting to certiorari, unless exceptional circumstances justify its omission.