Cebu Woman's Club v. De La Victoria
REITERATIONFacts
The Antecedents: Petitioner Cebu Woman's Club (CWC) contracted respondent CAMSAC International, Inc. (CAMSAC) for the construction of a building. A sub-contract agreement was later entered into by CAMSAC with respondent Phanuel Señoron. CWC received demand letters from suppliers-creditors and CAMSAC for the release of the 10% retention fee stipulated in the construction contract. Meanwhile, Señoron filed a complaint against CWC and CAMSAC, seeking to prevent the release of the retention fee to CAMSAC. CAMSAC also filed a separate action against CWC for failure to release the retention fee. Procedural History: CWC filed a complaint for interpleader and damages against CAMSAC and other parties to determine their respective claims on the retention fee. The Regional Trial Court (RTC), Branch 6, Cebu City, dismissed CWC's complaint for interpleader, citing the pendency of Civil Case No. CEB-17079 filed by Señoron, to prevent multiplicity of suits. The RTC held that CWC should have filed an answer, counterclaim, or cross-claim in the Señoron case, or allowed other defendants to intervene therein. CWC's motion for reconsideration was denied. The Petition: CWC filed a petition for review on certiorari with the Supreme Court, assailing the RTC's Orders dismissing its complaint for interpleader. CWC argued that the RTC acted with grave abuse of discretion, had no jurisdiction to dismiss the case motu proprio, erred in correlating the allegations of fact between the two cases, and that the dismissal amounted to a judgment on the pleadings without a hearing.
Issue(s)
Whether the respondent court acted with grave abuse of discretion and without jurisdiction in dismissing petitioner's action for interpleader, including the propriety of direct resort to the Supreme Court and the nature of the issues raised. Whether the respondent court erred in correlating the allegations of fact between the interpleader case and the pending case filed by respondent Señoron, and whether the alleged grave abuse of discretion and lack of jurisdiction were properly raised. Whether the respondent court's dismissal order, issued without a hearing, amounted to a judgment on the pleadings, considering the observance of the hierarchy of courts.
Ruling
The petition is denied for lack of merit. The Supreme Court affirmed the dismissal of the interpleader case by the RTC.
Ratio Decidendi
On the propriety of direct resort to the Supreme Court and the nature of the issues raised; and whether the respondent court acted with grave abuse of discretion and without jurisdiction in dismissing petitioner's action for interpleader: The Supreme Court held that petitioner's direct resort to the Court via a petition for review on certiorari was erroneous. Under the Rules of Court, direct appeals to the Supreme Court are allowed only on pure questions of law. The issues raised by petitioner, particularly whether the pending cases involved the same matters as the interpleader case and whether they arose from the same facts and circumstances, were factual in nature. The Supreme Court emphasized that it is not a trier of facts, and such factual determinations are within the purview of the lower courts. The Court cited Laza, et. al. v. Court Appeals et. al. and Dela Torre v. Pepsi Cola Products Phils., Inc. to support this principle. On the alleged grave abuse of discretion and lack of jurisdiction; and whether the respondent court erred in correlating the allegations of fact between the interpleader case and the pending case filed by respondent Señoron: The Court clarified that the imputation of grave abuse of discretion was a misplaced attempt to justify the erroneous mode of appeal. Grave abuse of discretion or errors of jurisdiction are correctable only by a special civil action of certiorari under Rule 65, not by an appeal under Rule 45. The Court found that the RTC had jurisdiction over the interpleader case. Moreover, the alleged failure of the RTC to observe the proper procedure for an interpleader action, if true, would constitute an error of judgment, not grave abuse of discretion, and is correctible by ordinary appeal. The Court reiterated that the extraordinary writ of certiorari does not issue to correct errors of procedure or mistakes in the findings and conclusions of a judge, citing Lalican v. Vergara et. al. and Chua v. Court of Appeals. On the observance of the hierarchy of courts; and whether the respondent court's dismissal order, issued without a hearing, amounted to a judgment on the pleadings: The Supreme Court further noted that even if the petition were treated as one for certiorari, petitioner should have observed the hierarchy of courts. The Court of Appeals has concurrent original jurisdiction with the Supreme Court and the Regional Trial Courts over special civil actions for certiorari. Petitioner's immediate recourse to the highest tribunal bypassed the appellate court, which is contrary to the established principle of judicial hierarchy. The Court cited Morales v. Court of Appeals et. al. in this regard. The Court also pointed out that in a petition for review on certiorari, the trial judge should not have been impleaded as a respondent, as was erroneously done by the petitioner.
Main Doctrine
A direct resort to the Supreme Court via petition for review on certiorari from a trial court's order dismissing an interpleader case is erroneous if the issues involve questions of fact, necessitating a determination of whether pending cases involve the same matters. Such errors of judgment are correctible by ordinary appeal, not by certiorari, which is reserved for grave abuse of discretion or errors of jurisdiction. Furthermore, the hierarchy of courts must be observed, with the Court of Appeals having concurrent original jurisdiction over certiorari petitions.