San Luis v. Court of Appeals
REITERATIONFacts
The Antecedents: The underlying dispute arose when T.N. Lal & Co., Ltd. filed a petition for indirect contempt against Antonio C. San Luis, Administrator of the Light Rail Transit Authority (LRTA). This action was based on San Luis' alleged failure to comply with a prior order from the Regional Trial Court (RTC) of Pasay City, Branch 111, which directed the LRTA to restore the power supply to T.N. Lal & Co., Ltd.'s sound system. Procedural History: The petition for indirect contempt was initially filed before the RTC of Pasay City, Branch 118. However, Judge Nelson Bayot of Branch 118 ordered the transfer of the case to Branch 111, citing that Branch 111 had issued the original order and was thus better positioned to determine if it had been violated. San Luis moved for reconsideration, which Judge Bayot denied, stating the records had already been transferred. San Luis then filed a special civil action for certiorari and mandamus with the Court of Appeals (CA) seeking to annul Judge Bayot's orders. The Petition: San Luis filed a petition for certiorari and mandamus with the Court of Appeals under Rule 65 of the Rules of Court, arguing that Judge Bayot acted without or in excess of jurisdiction by not acting on his motion to dismiss and motion for reconsideration, and instead transferring the case. The CA dismissed this petition, finding it was filed out of time. San Luis is now before the Supreme Court, seeking a liberal application of procedural rules and arguing that the CA erred in dismissing his petition due to a mistake in computing the filing period, and that the case should be decided on its merits.
Issue(s)
Whether the Court of Appeals gravely abused its discretion in dismissing the petition for certiorari and mandamus for failure to file the same on time. Whether the instant case warrants a liberal application of procedural rules to reinstate the petition for certiorari and mandamus before the Court of Appeals; specifically, whether Judge Nelson Bayot committed grave abuse of discretion in ordering the transfer of the petition for indirect contempt to Branch 111.
Ruling
The Supreme Court set aside the Resolutions of the Court of Appeals dated January 24, 2000, and March 13, 2000, and ordered the dismissal of CA-G.R. SP No. 56549. It affirmed the orders of public respondent Judge Nelson Bayot dated July 15, 1999, and October 22, 1999, in Civil Case No. 99-0480. The Presiding Judge of Branch 111, RTC of Pasay City, was directed to conduct appropriate proceedings in Civil Case No. 99-0480, including the resolution of petitioner's motion to dismiss.
Ratio Decidendi
On the issue of timeliness of the petition for certiorari and mandamus: The Court ruled in favor of the petitioner on the procedural aspect. The Court of Appeals reckoned the 60-day period from petitioner's receipt of the July 15, 1999 order, considering the interruption by the motion for reconsideration, and calculated the remaining period from November 8, 1999. However, the Court pointed out that Section 4, Rule 65 of the Rules of Court was amended by A.M. No. 00-2-03-SC, effective September 1, 2000. Under the amended rule, the 60-day period is counted from the notice of denial of the motion for reconsideration. This amendment was made applicable to pending cases, such as the case at bar, as it is a procedural law. Therefore, the 60-day period should have been counted from November 8, 1999, the date petitioner received the order denying his motion for reconsideration. The petition filed on January 7, 2000, was therefore filed within the reglementary period. On the merits of the petition for certiorari and mandamus (Grave Abuse of Discretion): The Court found that public respondent Judge Nelson Bayot committed no error and did not act with abuse of discretion in ordering the transfer of the petition for indirect contempt to Branch 111. The Court cited Sections 4 and 5 of Rule 71 of the Rules of Court. Section 4 states that charges for indirect contempt shall be commenced by a verified petition, and if related to a principal action, it shall be docketed and heard separately unless consolidated. Section 5 provides that where contempt has been committed against a Regional Trial Court, the charge may be filed with such court. The Court emphasized that contempt proceedings are sui generis and are triable only by the court against whose authority the contempt is charged. The power to punish for contempt rests exclusively with the court contemned, as it is that court which can determine whether its order has been violated. Therefore, Judge Bayot correctly transferred the case to Branch 111, which issued the original order, as it was in the best position to determine whether its order had been violated and if contempt was committed.
Main Doctrine
The amended Section 4 of Rule 65 of the Rules of Court, which provides that the 60-day period for filing a petition for certiorari shall be counted from notice of the denial of a motion for reconsideration, is applicable to pending cases and is procedural in nature, thus having retroactive effect.