Cabellan v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the possession of a 50-square-meter parcel of land in Suarez, Iligan City. Nathaniel Dinoro acquired rights to this land by purchase. Romeo Cabellan had been occupying the land since 1968 through tolerance. After Dinoro's purchase in May 1986, he requested Cabellan to vacate, which Cabellan refused. Conciliation efforts at the barangay level failed, leading to judicial proceedings. 2. Procedural History: Nathaniel Dinoro filed an unlawful detainer case against Romeo Cabellan before the Municipal Trial Court (MTC), Branch II, Iligan City. The MTC ruled in favor of Dinoro on December 22, 1987, ordering Cabellan's ejectment and payment of fees and monthly rentals. Cabellan appealed to the Regional Trial Court (RTC), Branch III, Iligan City. Initially, the RTC reversed the MTC decision but later reconsidered and dismissed Cabellan's appeal. Following the RTC's dismissal, Dinoro moved for execution, which the MTC granted. Subsequently, Cabellan filed a petition for certiorari with the Court of Appeals (CA) to nullify the RTC's order. 3. The Petition: This case reaches the Supreme Court via a petition for review, challenging the Court of Appeals' decision dated October 31, 1989, which dismissed Cabellan's special civil action for certiorari. Cabellan argued that the land in question is government-owned, thus divesting the MTC and RTC of jurisdiction. He also contended that the RTC's order and the CA's decision were void. The CA dismissed the certiorari petition, finding it an improper remedy and noting that even if treated as a petition for review, it was filed out of time and lacked the required material dates. The CA also found no grave abuse of discretion by the respondent court. The Supreme Court, in turn, affirmed the CA's decision, holding that the public character of the land does not preclude courts from exercising jurisdiction over possessory actions and that Cabellan's petition was a substitute for a lost appeal, filed beyond the reglementary period.
Issue(s)
Whether the Municipal Trial Court (MTC) and Regional Trial Court (RTC) had jurisdiction over the ejectment case despite petitioner's claim that the land is owned by the government. Whether the petition for certiorari filed in the Court of Appeals was the proper remedy and if it was filed within the reglementary period. Whether the Court of Appeals erred in dismissing the petition for certiorari.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals. The petition for review was dismissed for lack of merit.
Ratio Decidendi
On the jurisdiction of the MTC and RTC over the ejectment case: The Court held that the public character of the land in dispute does not exclude courts from their jurisdiction over possessory actions. In ejectment cases, the sole issue is possession, irrespective of claims of ownership. The government cannot be prejudiced by a ruling on possession, as such judgments are binding only with respect to the issue of possession. The RTC correctly considered the public character of the land irrelevant in the ejectment case, focusing instead on the better right of possession of the private respondent, evidenced by a deed of sale, tax declaration, and tax receipts, compared to the petitioner's lack of proof of ownership or authority from the government. On the propriety and timeliness of the petition for certiorari: The Court found that the petition for certiorari was not the proper remedy and was used as a substitute for a lost appeal. Petitioner failed to appeal the RTC's decision, which had become final and executory. The petition for certiorari was filed more than seven months after the RTC affirmed the MTC's decision, an unreasonable period for such a petition. Furthermore, even if treated as a petition for review, it was dismissed by the CA for late filing of the petition and docket fees, and for failing to state material dates showing timely filing, as required by the Revised Internal Rules of the Court of Appeals. On the Court of Appeals' dismissal of the petition: The Court found no error in the CA's dismissal. The CA correctly applied the rules regarding the timeliness and form of petitions for review and certiorari. The right to appeal is a privilege that must be exercised within the manner prescribed by law, and non-compliance with these requirements renders the judgment final and executory. The CA acted within its appellate jurisdiction and did not commit grave abuse of discretion.
Main Doctrine
The public character of the land in dispute does not exclude courts from their jurisdiction over possessory actions, as the only issue in ejectment cases is possession, regardless of the claim of ownership. A petition for certiorari cannot be used as a substitute for a lost appeal, especially when filed beyond the reglementary period.