Angara v. Fedman Development Corporation
REITERATIONFacts
The Antecedents: Respondent Fedman Development Corporation filed a complaint for Accion Reinvindicatoria and/or Quieting of Title against petitioner Edgardo J. Angara. Respondent alleged that it is the registered owner of several lots in Nasugbu, Batangas, and discovered in August 1995 that petitioner had fenced these parcels of land without its consent. Despite respondent informing petitioner of its title and conducting a relocation survey confirming the encroachment, petitioner refused to vacate the property. Procedural History: The case was initially filed before the Regional Trial Court (RTC), Branch 14, Nasugbu, Batangas. The RTC ordered a ground relocation survey and later a committee of three surveyors to conduct a survey. After the submission of individual reports and a subpoena for the surveyors to testify, the RTC initially dismissed the case for failure to prosecute but reconsidered. Petitioner then filed an Omnibus Motion praying for judgment based on the commissioners' report or, alternatively, for the impleading of adjoining property owners. The RTC denied this motion, stating that no joint survey was conducted and that impleading other owners would complicate the case. Petitioner's motion for reconsideration was also denied. Aggrieved, petitioner filed a petition for certiorari with the Court of Appeals (CA), which dismissed the petition, affirming the RTC's orders. The CA ruled that the records contradicted petitioner's claim about the survey and that adjoining owners were not indispensable parties. Petitioner's subsequent motion for reconsideration with the CA was also denied. The Petition: Petitioner filed a petition for review on certiorari with the Supreme Court, seeking reconsideration of the Court's prior resolution that denied his petition for review. He argued that the CA erred in not finding that the RTC acted with grave abuse of discretion. Specifically, he contended that the RTC improperly ignored the commissioners' report without a valid explanation and wrongly refused to direct the respondent to implead adjoining property owners who were allegedly affected by the survey. Petitioner also argued that the issue of overlapping boundaries should be determined by technical experts. The Supreme Court, in its resolution, denied the motion for reconsideration, finding that the RTC's orders were interlocutory and that certiorari was not the proper remedy for errors of judgment, and that petitioner failed to demonstrate grave abuse of discretion.
Issue(s)
Whether the Court of Appeals erred in failing to declare that the orders of the RTC were rendered without or in excess of jurisdiction, or with grave abuse of discretion. Whether the RTC committed grave abuse of discretion in refusing to render judgment based on the commissioners' report. Whether the RTC committed grave abuse of discretion in refusing to direct respondent to implead adjoining property owners.
Ruling
The Supreme Court denied the Motion for Reconsideration for lack of merit. It affirmed the Court of Appeals' dismissal of the petition for certiorari, upholding the Regional Trial Court's orders.
Ratio Decidendi
On the Court of Appeals' alleged error: The Court reiterated that a petition for certiorari under Rule 65 is a remedy of limited scope, primarily to correct errors of jurisdiction or grave abuse of discretion amounting thereto. The RTC's orders denying judgment based on the commissioners' report were interlocutory, as they did not terminate the proceedings. Ordinarily, the remedy against such orders is appeal after an unfavorable verdict, not certiorari, unless special circumstances render appeal inadequate. The Court found no such special circumstances. The Court noted that the RTC's orders were not patently or grossly arbitrary, nor did they constitute an evasion of a positive duty. On the RTC's refusal to render judgment based on the commissioners' report: The trial court is not bound by the findings of commissioners and may adopt, modify, or reject their report. The RTC's decision not to give credence to the report, based on its finding that a joint survey was not conducted as ordered, was an exercise of judgment within its jurisdiction, not a grave abuse of discretion. On the RTC's refusal to implead adjoining property owners: The Court found that Angara failed to demonstrate grave abuse of discretion by the RTC in denying his prayer to implead adjoining property owners. The RTC correctly observed that Angara did not identify the specific property owners who would be affected by the suit. A blanket inclusion of all property owners in the barangay was not warranted. It was Angara's responsibility to name the persons he claimed would be affected. Moreover, Angara failed to show positively that these adjoining owners had such an interest in the controversy or subject matter that a final adjudication could not be made without affecting their rights, or that they ought to be joined for complete relief. Crucially, since the RTC did not adopt the surveys and reports of the individual commissioners, the observation of one surveyor regarding indispensable parties was not given credence, as the report did not comply with the order for a joint survey. Therefore, the joinder of adjoining owners was not warranted at that stage.
Main Doctrine
A petition for certiorari under Rule 65 is a remedy narrow in scope and inflexible in character, intended to keep an inferior tribunal within its jurisdiction. It cannot be invoked to correct errors of judgment or procedure, or to review the intrinsic correctness of a lower court's decision upon law or facts, unless such errors amount to grave abuse of discretion equivalent to lack or excess of jurisdiction. Interlocutory orders, which do not end the proceedings, are generally not reviewable by certiorari, but by appeal after an unfavorable verdict, unless special circumstances demonstrate the inadequacy of appeal.