Serondo v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a fishpond area, a portion of the public domain, which became the subject of conflicting claims. Carmen Claro, who acquired rights from the Suison spouses, filed a fishpond application. Subsequently, respondent Jose Gulmatico also filed an application for the same area. The Philippine Fisheries Commission (PFC) initially rejected Claro's application, and later, its successor, the Bureau of Fisheries and Aquatic Resources (BFAR), denied Claro's motion for reconsideration and gave due course to Gulmatico's application. 2. Procedural History: After Carmen Claro sold her rights to Jovito Burgas, and Burgas subsequently sold to spouses Miller and Adelie Serondo, various petitions and appeals ensued. The Department of Agriculture denied Burgas' petition for cancellation of Gulmatico's Fishpond Lease Agreement (FLA). The Office of the President dismissed the appeal of Burgas and Serondo, affirming the denial and ruling that Burgas and Serondo had no valid claim, partly due to procedural defects and the invalidity of their predecessors' rights. Petitioners then filed a complaint for certiorari and prohibition with the Regional Trial Court (RTC), seeking to void Gulmatico's FLA. The RTC denied the Republic's motion to dismiss. The Republic then filed a petition for certiorari with the Court of Appeals (CA), which set aside the RTC's orders and dismissed the complaint. 3. The Petition: The petitioners, spouses Miller and Adelie Serondo, are before this Court via a petition for review on certiorari, challenging the Court of Appeals' decision. They argue that the CA erred in failing to rule on the trial court's power to determine when the subject land was classified and released as alienable and disposable land. The petitioners contend that the CA should have allowed the trial court to proceed with determining the factual issue of land classification, rather than dismissing their complaint outright. They seek to have the FLA issued to Gulmatico declared void.
Issue(s)
Whether the Court of Appeals erred in failing to rule on the power of the trial court to determine the conflicting versions as to when actually the subject land was classified and released as alienable and disposable land. Whether petitioners had the legal standing to file a petition for certiorari before the trial court.
Ruling
The Supreme Court denied the petition for lack of merit. The Court held that the issue raised by the petitioners was factual, which it may not review. The Court further affirmed the Court of Appeals' ruling that petitioners were not parties before the offices a quo whose decisions were sought to be annulled, and thus had no standing or personality to avail themselves of the remedy of certiorari before the trial court. Their proper remedy was to appeal the decision of the Office of the President to the Court of Appeals.
Ratio Decidendi
On the issue of the Court of Appeals' failure to rule on the trial court's power to determine land classification: The Supreme Court ruled that the question of whether the fishpond area in question was included in the aggregate area classified for fishpond development on May 3, 1984, is a factual question. The Court reiterated its policy that it is not a trier of facts and may not review factual issues, especially in petitions for certiorari. The Court emphasized that the decision of the Office of the President could be appealed to the Court of Appeals pursuant to Batas Pambansa Blg. 129, and that the ruling of the Office of the President did not involve actions and decisions of the Director of Fisheries and Aquatic Resources and the Secretary of Agriculture affecting fishing and fisheries, thus making BP 129 the pertinent statute. The Court found that the CA correctly determined that the issue of land classification was factual and thus beyond its scope of review in a certiorari proceeding, and that the petitioners' recourse was to appeal the decision of the Office of the President to the CA. On the issue of petitioners' standing to file a petition for certiorari before the trial court: The Supreme Court affirmed the Court of Appeals' ruling that the petitioners, spouses Serondo, had no legal standing or personality to file a petition for certiorari before the Regional Trial Court. This was because they were not parties to the administrative proceedings before the offices a quo whose decisions they sought to annul. The Court cited the principle that an intervention may be allowed only before or during trial, not when a case is already in its appellate stage. Since Serondo filed her petition for intervention after the issuance of the appealed order and during the pendency of the appeal, she had no personality to invoke the appellate jurisdiction of the Office of the President. Consequently, not being parties in the original proceedings, they could not directly assail the administrative decisions through a petition for certiorari before the trial court. Their proper remedy was to appeal the final decision of the Office of the President to the Court of Appeals, as provided by law.
Main Doctrine
A party seeking to intervene in an administrative proceeding must possess legal interest and must file the petition within the prescribed period. Furthermore, a petition for certiorari before the Regional Trial Court is not the proper remedy to assail decisions of administrative bodies when the proper remedy is an appeal to the Court of Appeals.