Urethane Trading Specialist v. Ong
REITERATIONFacts
The Antecedents: This case originated from a complaint for a sum of money filed by Urethane Trading Specialist, Inc. (petitioner) against Edwin Ong and Leticia Ong (respondents) in June 2000. The petitioner sought to recover P295,026.01, plus legal interest and attorney's fees. The Metropolitan Trial Court (MeTC) declared the respondents in default and, after receiving evidence ex parte, rendered a decision in favor of the petitioner on October 30, 2001, ordering the respondents to pay the claimed amount. Procedural History: Following the finality of the MeTC decision, the petitioner moved for its execution, which was granted by the MeTC on March 18, 2002. Subsequently, on July 9, 2002, the respondents filed a petition for annulment of judgment with damages and a prayer for injunctive relief before the Regional Trial Court (RTC), alleging they never received the summons and that the sheriff's return was fabricated. The petitioner moved to dismiss this petition, arguing it was barred by the statute of limitations and that the claims were waived or abandoned. The RTC denied the motion to dismiss, and its subsequent motion for reconsideration was also denied. The petitioner then filed a petition for certiorari with the Court of Appeals (CA), which dismissed the petition, holding that an interlocutory order is not subject to certiorari. The CA also denied the petitioner's motion for reconsideration. The Petition: The petitioner filed the present petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's dismissal of its petition for certiorari. The petitioner raises two main issues: (1) whether the respondents' petition for annulment of judgment should have been dismissed on grounds of prescription or laches, and waiver, abandonment, or extinguishment of claims; and (2) whether the CA erred in dismissing its petition for certiorari on the ground that the RTC's denial of the motion to dismiss was an interlocutory order.
Issue(s)
Whether the petition for annulment of judgment should be dismissed on the grounds of prescription or laches, and waiver, abandonment, or extinguishment of the claim. Whether the petition for certiorari filed before the Court of Appeals should have been dismissed on the ground that an order denying a motion to dismiss is an interlocutory order.
Ruling
The Court denies the petition and affirms the ruling of the Court of Appeals.
Ratio Decidendi
On the issue of whether the petition for annulment of judgment should be dismissed on grounds of prescription, laches, waiver, or abandonment: The Court found that the grounds raised in the motion to dismiss, namely, prescription, laches, waiver, abandonment, or extinguishment of claim, were based on petitioner's assertion that respondents could not validly invoke lack of jurisdiction over their persons. This assertion is a conclusion of law that requires proof and resolution by the trial court. The allegations regarding the actual receipt of summons and voluntary submission to the MeTC's jurisdiction are matters of evidence that necessitate a full-blown trial. Therefore, these issues, including laches, abandonment, and prescription, cannot be resolved in a mere motion to dismiss, as they involve evidentiary matters that require a trial on the merits. Prescription will only warrant dismissal if the complaint on its face shows that the action has already prescribed. On the issue of whether the petition for certiorari should have been dismissed: The Court reiterated the well-entrenched rule that the denial of a motion to dismiss cannot be questioned in a certiorari proceeding under Rule 65 of the Rules of Court, as certiorari is designed to correct errors of jurisdiction, not errors of judgment. The appropriate recourse is to file an answer and interpose the objections as affirmative defenses, and if the decision is adverse, to elevate the matter on appeal. The Court emphasized that this rule admits of an exception only when the trial court gravely abused its discretion in denying the motion, which requires a clear showing of arbitrary or despotic exercise of judicial power, a standard not met in this case. The CA correctly dismissed the petition for certiorari on this ground.
Main Doctrine
The denial of a motion to dismiss, absent grave abuse of discretion, cannot be questioned through a petition for certiorari; the proper recourse is to file an answer and raise the issues as affirmative defenses, and if the decision is adverse, to appeal.