Venturanza v. Court of First Instance of Batangas
REITERATIONFacts
The Antecedents: Ruperto Venturanza was elected president of the municipality of Lemery, Batangas. Ramon Cabrera instituted a protest against Venturanza's election, which resulted in Venturanza's defeat and Cabrera's seating as municipal president. Procedural History: During the election contest, Cabrera filed a "counter-protest" alleging irregularities and frauds in districts not mentioned in the original protest. The respondent court, on objection, struck out this counter-protest. The election contest proceeded to trial, and the court rendered a decision in favor of the contestant (Cabrera). The Petition: Venturanza filed a petition for a writ of certiorari with the Supreme Court, seeking to review the proceedings in the Court of First Instance of Batangas, specifically the act of striking out or refusing to receive his counter-protest.
Issue(s)
Whether the Court of First Instance acted without or in excess of its jurisdiction in striking out the counter-protest of the petitioner in an election contest, thereby justifying the issuance of a writ of certiorari.
Ruling
The petition for a writ of certiorari is denied. The Supreme Court held that the Court of First Instance of Batangas did not act without or in excess of its jurisdiction when it struck out the counter-protest. While the act may have been erroneous, it was not an act outside the court's jurisdiction. The proceeding is dismissed.
Ratio Decidendi
On Issue 1: The Supreme Court held that the petitioner was not entitled to the remedy of certiorari because there was no showing that the trial court acted without or in excess of its jurisdiction. Citing a long line of precedents, including Herrera v. Barretto and Joaquin, the Court emphasized that jurisdiction is the power to hear and determine a cause, and this power does not depend on the correctness of the decision reached. In this case, the Court of First Instance of Batangas clearly possessed jurisdiction over both the subject matter of the municipal election protest and the parties involved. The act of striking out a counter-protest, while potentially an error of law, remains an act performed within the court's jurisdictional sphere. The Court noted that it did not need to decide whether the striking of the pleading was actually erroneous, as certiorari is not the appropriate vehicle for correcting mere errors of judgment. Applying the established rule, the Court concluded that because the trial court did not step outside its jurisdictional boundaries, the extraordinary writ of certiorari cannot be issued to review the proceedings. Therefore, the petitioner failed to satisfy the essential requirement for the writ, which is the presence of an act performed without or in excess of jurisdiction.
Main Doctrine
A writ of certiorari will not issue to an inferior court unless that court acted without or in excess of its jurisdiction in performing the acts complained of. An erroneous act, if within the court's jurisdiction, is not a ground for certiorari.