Regis v. Garcia
REITERATIONFacts
The Antecedents: This case involves two ejectment cases between Felipe Regis, Jr. (Regis) and Agapito Garcia (Garcia) concerning a parcel of land in Iligan City. The first case, Civil Case No. II-236, was a complaint for forcible entry filed by Regis's parents against Garcia. The Municipal Trial Court in Cities (MTCC), Branch II, Iligan City, dismissed the case on March 13, 1989, finding Garcia to be the owner and possessor of the 200-square-meter lot since 1947, which was awarded to him under a Miscellaneous Sales Application. This decision became final and executory as no appeal was taken. Procedural History: The second case, Civil Case No. 1-429, was an ejectment case filed by Garcia against Regis and his family with the MTCC, Branch 01, Iligan City. The MTCC dismissed Garcia's complaint on February 11, 1999, for failure to prove prior physical possession. Garcia appealed to the Regional Trial Court (RTC), Branch 03, Iligan City. The RTC reversed the MTCC decision on September 2, 1999, ordering Regis to vacate the property, taking into account the prior MTCC decision in Civil Case No. II-236 which established Garcia's prior possession since 1946. Regis appealed to the Court of Appeals (CA), which affirmed the RTC decision on September 13, 2001. Regis's motion for reconsideration was denied by the CA on February 15, 2002. The Petition: Regis filed a petition for certiorari under Rule 65 of the Rules of Court before the Supreme Court, assailing the CA's decision and resolution. He argued that the CA lacked jurisdiction by deciding the forcible entry case as an accion publiciana and that his constitutional rights to due process and a day in court were violated. He also questioned the CA's finding of prior possession by Garcia.
Issue(s)
Whether the Court of Appeals committed a grave abuse of discretion amounting to lack of jurisdiction in deciding CA-G.R. SP No. 57003, an appealed forcible entry case, thereby violating petitioner's constitutional rights to due process and to a day in court. Whether the Court of Appeals erred in holding that respondent Garcia had prior possession of the disputed 40-square-meter lot.
Ruling
The petition is devoid of merit. The Supreme Court affirmed the Decision of the Court of Appeals, dated September 13, 2001, and the Resolution dated February 15, 2002, in CA-G.R. SP No. 57003.
Ratio Decidendi
On the issue of jurisdiction and constitutional rights: The Supreme Court reiterated that a petition for certiorari under Rule 65 cannot be used as a substitute for the lost remedy of appeal. Regis filed the petition for certiorari after his motion for reconsideration was denied, and his arguments primarily questioned matters of law, which should have been raised through a petition for review on certiorari under Rule 45. The Court clarified that the CA did not treat the forcible entry case as an accion publiciana; it merely commented on the RTC's observation. The CA acted within its jurisdiction by ruling on the forcible entry case, and Regis, having participated in the proceedings, is estopped from assailing the CA's jurisdiction. Therefore, Regis was not deprived of due process or his day in court. On the issue of prior possession: The Supreme Court held that the findings of fact of the trial court, especially when adopted and affirmed by the Court of Appeals, are final and conclusive and cannot be reviewed on appeal. The Court took judicial notice of the MTCC Decision in Civil Case No. II-236, which had become final and executory. This decision established that Garcia was the owner of the 200-square-meter lot, that the contested 40-square-meter lot was part of it, and that Garcia's possession dated back to 1946, while Regis's possession began later in 1962. Consequently, Regis was barred by res judicata from questioning these findings, and the Court upheld the concurrent findings of the MTCC, RTC, and CA regarding Garcia's prior possession.
Main Doctrine
A petition for certiorari under Rule 65 cannot be availed of as a substitute for the lost remedy of appeal, especially when the arguments presented question matters of law that should have been raised through a petition for review on certiorari under Rule 45. Furthermore, findings of fact of the trial court, especially when adopted and affirmed by the Court of Appeals, are final and conclusive and may not be reviewed on appeal by the Supreme Court.