Macawiag v. Balindong
REITERATIONFacts
The Antecedents: Private respondent Soraida Macawiag and Pangampong Macawiag were married on May 27, 1987. Private respondent claimed that the customary dower (mahr) included P20,000.00 cash, one carabao, and a house and lot located at Mahayahay, Iligan City, covered by TCT No. T-28,147(a.f.). Petitioner Mocaral Macawiag and her children refused to recognize the house and lot as part of the mahr. Prior to filing the action, Pangampong Macawiag executed an affidavit of loss of the title, and a new duplicate title was issued. Petitioner and her children denied the mahr included the house and lot, claiming the dowry was only P5,000.00 cash. They also alleged the title was used as collateral for a P500,000.00 loan, with P400,000.00 given to Pangampong Macawiag, and that petitioner took possession of the vehicle when Pangampong failed to pay the amortization. Witnesses for private respondent testified that the house and lot were indeed part of the mahr. Witnesses for petitioner denied this and testified that the property was mortgaged to Antonio Camama, who eventually executed a Deed of Absolute Sale in his favor. Procedural History: The Fourth Shari'a Circuit Court ruled in favor of petitioner, declaring the house and lot not part of the mahr and ordering private respondent to pay attorney's fees. The Shari'a District Court reversed this decision, declaring private respondent the exclusive owner of the house and lot as her mahr and ordering defendants to pay attorney's fees and litigation expenses. The Petition: Petitioner filed a petition for certiorari under Rule 65, seeking to nullify the decision of the Shari'a District Court, alleging grave abuse of discretion amounting to lack of jurisdiction or excess thereof.
Issue(s)
Whether the Shari'a District Court acted with grave abuse of discretion amounting to lack of jurisdiction or excess thereof when it reversed the decision of the Shari'a Circuit Court; and whether the petition for certiorari under Rule 65 is the proper remedy, considering the availability of appeal and the finality of the Shari'a District Court's decision. Whether the children of Mocaral Macawiag, as heirs of Sarimanoc Macawiag, are indispensable parties to the petition.
Ruling
The petition is dismissed. The Supreme Court ruled that the proper remedy was a petition for review on certiorari under Rule 45, not a petition for certiorari under Rule 65, as the Shari'a District Court's decision was final and executory. The Court also noted the absence of indispensable parties.
Ratio Decidendi
On the propriety of the remedy and the finality of Shari'a District Court decisions: The Court held that a petition for certiorari under Rule 65 is not the proper remedy when the aggrieved party has a plain, speedy, and adequate remedy of appeal. The Shari'a District Court's decisions are final and executory, and can only be reviewed by the Supreme Court via a petition for review on certiorari under Rule 45, or in cases involving jurisdiction. Errors of judgment, which are committed in the exercise of jurisdiction, are not reviewable by certiorari. The petition filed by petitioner was filed beyond the reglementary period for a petition for review, and it improperly alleged "grave abuse of discretion" to mask an attempt to review factual findings. The Court reiterated that decisions of the Shari'a District Courts are final and executory, as provided by Article 145 of Presidential Decree No. 1083. While the Supreme Court retains original and appellate jurisdiction, this does not grant it the power to review a judgment that has acquired finality through a Rule 65 petition, unless there is a question of jurisdiction. The Court emphasized that allowing review of final and executory decisions would lead to endless litigation and undermine the rule of law. On indispensable parties: The Court noted that the complaint before the Shari'a Circuit Court included the children of Mocaral Macawiag as defendants, who are heirs of the late Sarimanoc Macawiag. However, the petition before the Supreme Court was filed only by Mocaral Macawiag, without impleading the other heirs. These other heirs are indispensable parties, whose absence prevents the Court from previewing the merits of the case. The Court cannot proceed to a review of the merits when essential parties to the controversy have not been included in the proceedings.
Main Doctrine
A petition for certiorari under Rule 65 is not the proper remedy when the aggrieved party has a plain, speedy, and adequate remedy of appeal. Errors of judgment are not reviewable by certiorari, which is limited to errors of jurisdiction. Decisions of Shari'a District Courts become final and executory and can only be reviewed by the Supreme Court via a petition for review on certiorari under Rule 45, or in cases involving jurisdiction.