Lim v. Garcia
REITERATIONFacts
The Antecedents: Carmelita V. Lim filed a Complaint Affidavit against Valentin Garcia for Falsification and Perjury, alleging Garcia willfully and deliberately asserted a falsehood in an affidavit submitted to the Register of Deeds concerning the loss of his owner's duplicate copy of TCT No. 107535. Subsequently, Garcia filed a counter-affidavit and complaint against Lim, Villamon Fernandez, and Corazon Rueda for Falsification of Public Document and Use of Falsified Document. The Provincial Prosecutor recommended the filing of an information for Violation of Article 183 of the Revised Penal Code against Garcia and dismissed the charges against Lim and others. Procedural History: On April 29, 1998, Garcia and his wife filed a Complaint before the RTC of Balanga, Bataan, for Delivery of the Owner's Duplicate Certificate of Title and Damages, involving the same TCT. Attached to the complaint was a Certification and Verification where Garcia stated he had not commenced any action or filed any claim involving the same issues in any court, tribunal, or quasi-judicial agency, except for pending criminal actions. Garcia later filed a Petition for Suspension of Criminal Action based on the pendency of the civil case, which was denied. Petitioners filed a Motion to Dismiss the civil case, alleging forum-shopping and extinguishment of the cause of action by previous sale. The RTC denied the motion to dismiss. Petitioners filed a Motion for Reconsideration, which was also denied. An Information for Violation of Article 183 of the Revised Penal Code was filed against Garcia. The Petition: Petitioners filed a Petition for Certiorari under Rule 65, assailing the RTC's Orders denying their Motion to Dismiss and Motion for Reconsideration. They alleged grave abuse of discretion for perfunctorily denying the motion without stating reasons, violation of the rule against forum-shopping, and extinguishment of the cause of action by previous sale.
Issue(s)
Whether the RTC committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying the Motion to Dismiss, including the propriety of the remedy and procedural deficiencies. Whether the private respondents violated the rule against forum-shopping. Whether the cause of action in the civil case had been extinguished by the previous sale of the property.
Ruling
The petition is DISMISSED. The Supreme Court found procedural deficiencies and no grave abuse of discretion on the part of the public respondent.
Ratio Decidendi
On the propriety of the remedy and procedural deficiencies, and the alleged grave abuse of discretion and the RTC's orders: The Supreme Court held that a petition for certiorari under Rule 65 is not the proper remedy for an alleged error of judgment, which should be corrected by appeal. The Court also emphasized the doctrine of judicial hierarchy. Furthermore, the petition was procedurally flawed for failing to attach copies of relevant pleadings. While acknowledging that the Order dated September 3, 1998, was defective, the Court noted that this error was corrected in the subsequent Order dated November 13, 1998. Even if the orders were erroneous, such errors would merely constitute errors of judgment, not errors of jurisdiction. On the issue of forum-shopping: The Court clarified that forum-shopping exists when the elements of litis pendentia are present. The Court found no identity of causes of action, issues, and reliefs prayed for between the criminal cases and the civil case. Therefore, private respondents were not mandated to disclose the status of the criminal cases in their verification. On the extinguishment of the cause of action: The Court held that the contention that the private respondents' complaint had been extinguished by the sale of the property to the petitioners is a matter best threshed out through a full-blown trial. This substantive issue could not be resolved in a motion to dismiss based on the pleadings presented.
Main Doctrine
A petition for certiorari under Rule 65 is not the proper remedy for an alleged error of judgment, which can only be corrected by appeal. Furthermore, a petition for certiorari must be filed with the proper court exercising original jurisdiction, observing the doctrine of judicial hierarchy, and must be accompanied by all relevant pleadings and documents.