Teotico v. Baer
REITERATIONFacts
1. The Antecedents: Respondent Rosario D. Baer filed a complaint against petitioner Josefina Teotico, administratrix of the estate of her late husband Francisco Santana, for specific performance and damages. Baer alleged that despite full payment for a residential lot, Teotico refused to execute an absolute deed of sale. Francisco Santana died during the pendency of the case. 2. Procedural History: The Housing and Land Use Regulatory Board (HLURB) rendered a default judgment against petitioner on May 25, 1998, for failure to file an answer. A writ of execution was issued, but petitioner opposed it, arguing the HLURB decision was void due to lack of proof of her administratrix status and improper service of summons. The HLURB denied her opposition. Petitioner then filed a petition for certiorari with the Court of Appeals (CA) under Rule 65, assailing the HLURB's default judgment and order for enforcement, alleging grave abuse of discretion. The CA dismissed the petition, finding that petitioner had not exhausted administrative remedies, specifically a petition for review within 30 days or an appeal to the Office of the President. Petitioner's motion for reconsideration was also denied by the CA. 3. The Petition: Petitioner seeks review on certiorari under Rule 45 of the Rules of Court, assailing the resolutions of the Court of Appeals. The core of the petition is that the CA erred in dismissing her case for failure to exhaust administrative remedies, arguing that the HLURB judgment was void and that there was an urgent need for judicial intervention. The petition contends that the CA should have addressed the merits of her claim rather than strictly applying the doctrine of exhaustion of administrative remedies.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari filed by petitioner. Whether petitioner failed to exhaust available administrative remedies. Whether certiorari can be used as a substitute for a lost remedy of appeal, and whether the HLURB judgment was null and void.
Ruling
The petition is denied for lack of merit. The Court of Appeals did not err in dismissing the petition for certiorari.
Ratio Decidendi
On the dismissal of the petition for certiorari: The Court of Appeals did not err in dismissing the petition for certiorari because the petitioner had other available remedies and failed to properly pursue them. On the failure to exhaust administrative remedies: The Court reiterated the principle of exhaustion of administrative remedies, mandating that administrative agencies be given the opportunity to resolve matters within their competence before judicial intervention. The HLURB has established rules of procedure for adjudication, and the petitioner failed to avail herself of the remedies provided, such as filing a petition for review with the HLURB and subsequently appealing to the Office of the President. Direct resort to the Court of Appeals via a petition for certiorari without exhausting these administrative remedies is fatal to the cause of action. The Court found no exceptional circumstances to justify exemption from this doctrine. On the use of certiorari as a substitute for appeal and the alleged nullity of the HLURB judgment: Certiorari under Rule 65 is an extraordinary remedy and cannot be used as a substitute for a lost or lapsed remedy of appeal, especially when the loss or lapse is attributable to the petitioner's own neglect. The petitioner had a remedy in the ordinary course of law, such as a petition for review within the administrative framework, which she failed to pursue. Furthermore, regarding the alleged nullity of the HLURB judgment, the petitioner failed to demonstrate any compelling reason to bypass the established administrative remedies. The procedural defects she alleged should have been raised through the proper administrative channels. Her failure to do so precluded their consideration through a petition for certiorari as a primary remedy.
Main Doctrine
A petition for certiorari under Rule 65 cannot be used as a substitute for a lost or lapsed remedy of appeal, especially if such loss or lapse was occasioned by one's neglect or error in the choice of remedies. The doctrine of exhaustion of administrative remedies requires that all available administrative remedies must be pursued before resorting to judicial action.