Triplex Enterprises, Inc. v. Philippine National Bank-Republic Bank
REITERATIONFacts
1. The Antecedents: Triplex Enterprises, Inc. (Triplex) sought to annul the sale of two parcels of land in Tagaytay City by PNB-Republic Bank to Solid Builders, Inc. Triplex claimed it was the highest bidder and should have been awarded the sale. PNB-Republic Bank rejected Triplex's bid, having already sold the properties to Solid Builders, Inc. 2. Procedural History: Triplex filed an action for annulment of contract, mandamus, and damages against PNB-Republic Bank and Solid Builders, Inc. before the Regional Trial Court (RTC) of Pasig City. During trial, Triplex attempted to present testimony regarding a legal opinion from the Office of the Government Corporate Counsel (OGCC) concerning the sale. The RTC sustained the respondents' objection to this testimony, citing the attorney-client privilege between the OGCC and PNB-Republic Bank. Triplex's motion for reconsideration was denied. Aggrieved, Triplex filed a petition for certiorari with the Court of Appeals (CA), which dismissed the petition. A subsequent motion for reconsideration was also denied, leading to the present petition. 3. The Petition: This case is before the Supreme Court on a petition for review on certiorari under Rule 45 of the Rules of Court. Triplex argues that the Court of Appeals erred in affirming the trial court's decision, which disallowed the presentation and admission of testimony concerning the OGCC's legal opinion. Triplex contends that the trial court committed grave abuse of discretion in excluding this evidence.
Issue(s)
Whether the Court of Appeals erred in ruling that the trial court did not commit grave abuse of discretion in disallowing the presentation and admission in evidence of Atty. Romeo Roque's testimony concerning the OGCC opinion. Whether an interlocutory order disallowing the admission of evidence can be assailed via a petition for certiorari.
Ruling
The petition is denied. The Court of Appeals did not err in dismissing the petition for certiorari. The trial court did not commit grave abuse of discretion in disallowing the testimony regarding the OGCC opinion, as such ruling was an error in judgment, not an error of jurisdiction, and is correctible only by appeal.
Ratio Decidendi
On whether the trial court committed grave abuse of discretion: The trial court's order disallowing the admission of testimony regarding the OGCC opinion was an exercise of its jurisdiction. Even if the order was erroneous, it constituted an error in judgment, not an error of jurisdiction. Therefore, it could not be corrected by a writ of certiorari. The petitioner's remedy was to assign this ruling as an error in the appeal from the final decision of the RTC on the merits of the case. The Court of Appeals correctly found no grave abuse of discretion on the part of the trial court. The petition for certiorari was thus correctly dismissed by the appellate court. On the propriety of certiorari to assail an interlocutory order disallowing evidence: Certiorari as a special civil action is proper only when a tribunal, board, or officer exercising judicial or quasi-judicial functions has acted without or in excess of jurisdiction, or with grave abuse of discretion, and there is no appeal nor any plain, speedy, and adequate remedy at law. The writ is restricted to truly extraordinary cases wherein the act of the lower court or quasi-judicial body is wholly void. It is designed to correct errors of jurisdiction and not errors in judgment. When a court has jurisdiction over the case and the person, any mistake in the application of the law and the appreciation of evidence committed by the court may be corrected only by appeal. The determination made by the trial court regarding the admissibility of evidence is an exercise of its jurisdiction, and any fault in making such determination is an error in judgment, not of jurisdiction. Therefore, rulings on the admissibility of evidence during trial are interlocutory and must be assigned as errors in the appeal from the final decision on the merits.
Main Doctrine
Rulings of the trial court on procedural questions and on admissibility of evidence during the course of a trial are interlocutory in nature and may not be the subject of a separate appeal or review on certiorari. They must be assigned as errors and reviewed in the appeal properly taken from the decision rendered by the trial court on the merits of the case.