Vios v. Pantangco
REITERATIONFacts
The Antecedents: Respondent Manuel Pantangco, Jr. (Pantangco) filed an ejectment case against petitioners Charlie Vios and Spouses Rogelio and Teresita Antonio (petitioners) for a residential land he purchased. Pantangco alleged that petitioners agreed to vacate within one week of his purchase, but they refused. Petitioners denied the allegations, claiming the property belonged to the government and Pantangco's title was fake. The Metropolitan Trial Court (MTC) ruled in favor of Pantangco, ordering petitioners to vacate and pay damages. Notices of the MTC decision were sent to the counsels of record. Atty. Genova received his copy on July 18, 1996, and Atty. Sollano received his on July 23, 1996. Pantangco filed a motion for execution, which the MTC granted, issuing a writ of execution. Petitioners moved to quash the writ, asserting the MTC decision had not become final as Vios had not been properly notified, and his counsel, Atty. Sollano, had withdrawn. The MTC denied the motion to quash, and possession was turned over to Pantangco. Procedural History: Petitioner Vios filed a Petition for Certiorari and Mandamus with the Regional Trial Court (RTC), assailing both the MTC decision and the writ of execution. The RTC annulled the MTC decision for being contrary to evidence and the writ of execution for being issued before the decision became final. The RTC ordered the restoration of possession to petitioners and directed Pantangco to exercise his options under Article 448 of the Civil Code. Pantangco filed a Motion for Reconsideration, which the RTC denied. Pantangco then filed a Petition for Declaration of Nullity of the RTC Decision with the Court of Appeals (CA), arguing that the RTC decision was void because the MTC decision could not be assailed via certiorari and that the RTC exceeded its jurisdiction by applying Article 448 without hearing the parties. The CA ruled that the MTC decision had not attained finality due to Vios's lack of full notification and that the writ of execution was invalid. However, the CA found that the RTC exceeded its jurisdiction by nullifying the MTC decision on the merits and by determining the parties' rights under Article 448. The CA declared the RTC decision void except for its nullification of the writ of execution. The Petition: Petitioners seek a review of the CA's decision, arguing that the CA erred in entertaining Pantangco's petition for nullity of the RTC decision when the proper remedy was an ordinary appeal, and thus the RTC decision had attained finality and became the law of the case.
Issue(s)
Whether the Court of Appeals erred in entertaining Pantangco's Petition for Declaration of Nullity of the RTC Decision when the proper remedy was an ordinary appeal. Whether the RTC decision, which was not appealed by Pantangco, had become final and executory and thus the law of the case. Whether the RTC exceeded its jurisdiction in annulling the MTC decision on the merits and in applying Article 448 of the Civil Code in a certiorari proceeding.
Ruling
The Supreme Court partially granted the petition. It declared the Court of Appeals in error for ruling on the merits of Pantangco's Rule 47 petition. However, it denied the petition insofar as it asked to recognize the RTC decision as fully valid and binding. The Court held that only the aspects relating to the lack of finality of the MTC decision and the invalidity of the writ of execution issued by the MTC are valid.
Ratio Decidendi
On the propriety of the CA entertaining Pantangco's Petition for Declaration of Nullity: The Court held that the CA erred in entertaining Pantangco's petition. The RTC decision in a certiorari case is a final order, and the proper remedy from such a decision is an ordinary appeal to the CA under Section 2, Rule 41 of the Revised Rules of Court. Pantangco's resort to a Petition for Declaration of Nullity of Judgment under Rule 47 was improper because an appeal was still available. Rule 47 is only available when ordinary remedies like appeal are no longer available through no fault of the petitioner. Since Pantangco failed to file an ordinary appeal, his chosen remedy was fatally defective. The Court emphasized that certiorari lies only when there is no appeal or any other plain, speedy, or adequate remedy. In this case, appeal was available and adequate. On whether the RTC decision became the law of the case: The Court clarified that the law of the case doctrine applies when an appellate court has made a ruling on a question on appeal and remands the case. This doctrine was not applicable here. The Court also addressed the petitioners' invocation of the doctrine of finality of judgment. However, it found that the RTC decision was partly void for lack of jurisdiction. Therefore, it could not be considered a final and controlling ruling that must govern the parties. The Court stated that a judgment must be valid to be considered final and immutable. On whether the RTC exceeded its jurisdiction: The Court affirmed that the RTC exceeded its jurisdiction in annulling the MTC decision on the merits and in applying Article 448 of the Civil Code. The Court reiterated that certiorari is a remedy for errors of jurisdiction, not errors of judgment. The RTC's review of the MTC decision on the merits was an error of judgment, which is not correctable through certiorari. The RTC's determination of the parties' rights under Article 448 was also beyond its certiorari jurisdiction, as this issue was not tackled by the MTC and was not a matter of correcting grave abuse of discretion. The Court held that the RTC's disposition on matters within its competence, such as the finality of the MTC decision and the validity of the writ of execution, were valid.
Main Doctrine
A petition for certiorari under Rule 65 is not a substitute for an ordinary appeal. The RTC, in a certiorari proceeding, cannot review the merits of the MTC decision. Its jurisdiction is limited to correcting errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction. An RTC decision in a certiorari case is a final order, and the proper remedy therefrom is an ordinary appeal to the Court of Appeals.