Fajardo v. Lim
REITERATIONFacts
The Antecedents: The City of Manila, under Mayor Gemiliano Lopez, implemented a "Land for the Landless Program" and decided to purchase squatter-infested properties, including lots owned by petitioners, the "Fajardo Estate." The City Appraisal Committee fixed the market value at P1,600.00 per square meter, and the city government subsequently purchased eight lots of the "Fajardo Estate" in two separate transactions in 1991 and 1992 for a total of P32,622,720.00. Mayor Lopez signed the disbursement voucher and PNB Check No. 906350 dated August 10, 1992, payable to petitioners, which was approved by the City Auditor. Procedural History: Upon assuming office on July 1, 1992, Mayor Alfredo Lim (respondent) instructed City Administrator Ramon V. Marzan (respondent) not to sign the check due to suspicions about the transaction, and Marzan informed petitioners. After petitioners sent a demand letter and the City Legal Officer opined there was no legal obstacle to release the check, Mayor Lim reiterated his instruction and directed an investigation. On October 20, 1992, petitioners filed a Petition for Mandamus With Damages against Mayor Lim and Marzan before the RTC, which ordered Marzan to countersign and deliver the check, awarded damages against Marzan personally, and absolved Mayor Lim of civil liability. Both parties appealed, and the Court of Appeals modified the RTC decision by deleting the award for damages, attorney's fees, and costs, and substituting the City Administrator for Marzan in the mandamus portion. Petitioners' motion for reconsideration was denied, and respondents Mayor Lim and Marzan filed a petition for review on certiorari with the Supreme Court (G.R. No. 120943), which was denied. Meanwhile, the Court of Appeals, in its Resolution dated October 16, 1995, declared it had lost jurisdiction over petitioners' motion for reconsideration because the case had been elevated to the Supreme Court. The Petition: Petitioners filed the instant petition raising two issues: (1) whether both respondents should be held liable jointly and severally for damages; and (2) whether the filing of a petition for review on certiorari by respondents with the Supreme Court divested the Court of Appeals of its jurisdiction.
Issue(s)
Whether both respondents should be held liable jointly and severally for damages. Whether the filing with the Supreme Court of a petition for review on certiorari by the respondents divested the Court of Appeals of its jurisdiction over the case.
Ruling
The petition is DENIED. The challenged Decision and Resolution of the Court of Appeals in CA-G.R. SP No. 34931 are AFFIRMED. Costs against petitioners.
Ratio Decidendi
On the first issue (liability for damages): The Court declined to delve into the issue of whether both respondents should be held liable jointly and severally for damages. It reiterated the well-established rule that its jurisdiction in cases brought via Rule 45 of the 1997 Rules of Civil Procedure is limited to reviewing errors of law, and it is not a trier of facts. Since the determination of liability for damages involves factual considerations, the Supreme Court found no reason to depart from the general rule and thus did not pass upon this specific claim. On the second issue (jurisdiction of the Court of Appeals): The Court affirmed the Court of Appeals' Resolution of October 16, 1995, wherein it declared that it had lost jurisdiction over the case. The Court explained that upon the seasonable filing of a petition for review on certiorari by respondents with the Supreme Court (G.R. No. 120943), the Supreme Court assumed jurisdiction over the case. This assumption of jurisdiction is irrespective of whether the petition would be given due course. The Court emphasized that this rule is crucial for the orderly administration of justice, preventing the possibility of conflicting resolutions between the Court of Appeals and the Supreme Court. Therefore, the Court of Appeals correctly recognized that it no longer had competence to act on the petitioners' motion for reconsideration.
Main Doctrine
Upon the filing of a petition for review on certiorari with the Supreme Court, the Court of Appeals loses jurisdiction over the case, regardless of whether the petition is given due course, to avoid conflicting resolutions and ensure orderly administration of justice.