Sevilleno v. Carilo
REITERATIONFacts
The Antecedents: Pamela and Purita Sevilleno filed a complaint for damages against spouses Camelo and Pacita Carilo, seeking P5,000.00 in actual damages, P400,000.00 in moral damages, P10,000.00 in exemplary damages, and P50,000.00 for attorney's fees. The respondents, in turn, prayed for the dismissal of the complaint due to a lack of cause of action. Procedural History: The Regional Trial Court (RTC), Branch 82, Quezon City, motu proprio dismissed the case on March 23, 1999, for lack of jurisdiction over the subject matter. A subsequent motion for reconsideration filed by the petitioners was denied by the RTC on May 18, 1999. The petitioners then appealed to the Court of Appeals. The Petition: The Court of Appeals dismissed the petitioners' appeal, holding that it was the wrong mode of appeal. The appellate court reasoned that since the core issue concerned the RTC's jurisdiction over the subject matter, which is a question of law, the appeal should have been filed directly with the Supreme Court under Rule 45 of the 1997 Rules of Civil Procedure, as amended, rather than an ordinary appeal under Rule 41 to the Court of Appeals. The Supreme Court denied the petition for review on certiorari, affirming the Court of Appeals' resolution.
Issue(s)
Whether the Court of Appeals erred in dismissing the petitioners' appeal. Whether the appeal raising only questions of law from a Regional Trial Court decision should be filed with the Court of Appeals or the Supreme Court.
Ruling
The petition is denied. The Resolution of the Court of Appeals dismissing the petitioners' appeal is affirmed.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in dismissing the petitioners' appeal: The Court of Appeals did not err in dismissing the appeal. The issue presented to the appellate court concerned the jurisdiction of the RTC over the subject matter of the case. It is a well-established rule that a court's jurisdiction over the subject matter is conferred by law, making any question related thereto a pure question of law. As the petitioners' appeal solely involved a question of law, they were mandated to file their appeal directly with the Supreme Court through a petition for review on certiorari under Rule 45 of the Rules of Civil Procedure. The appellate court correctly applied Section 2, Rule 50 of the Rules of Civil Procedure, which mandates the dismissal of an appeal erroneously taken to the Court of Appeals when it raises only questions of law. On the issue of whether the appeal raising only questions of law from a Regional Trial Court decision should be filed with the Court of Appeals or the Supreme Court: The appeal should have been filed directly with the Supreme Court. Section 2(c) of Rule 41 of the 1997 Rules of Civil Procedure explicitly states that in all cases where only questions of law are raised or involved, the appeal shall be to the Supreme Court by petition for review on certiorari in accordance with Rule 45. This is further clarified by jurisprudence, such as in Macawiwili Gold Mining and Development Co., Inc. v. Court of Appeals, which summarized that appeals from RTC decisions in the exercise of original jurisdiction, when raising only questions of law, must be taken to the Supreme Court on a petition for review on certiorari under Rule 45. The Court of Appeals, in cases involving only questions of law, does not have appellate jurisdiction. Therefore, the petitioners pursued the wrong mode of appeal by filing an ordinary appeal with the Court of Appeals.
Main Doctrine
An appeal from a Regional Trial Court decision raising only questions of law must be taken directly to the Supreme Court via a petition for review on certiorari under Rule 45, and not to the Court of Appeals by ordinary appeal under Rule 41. An appeal erroneously taken to the Court of Appeals raising only questions of law shall be dismissed outright.