Goco v. Court of Appeals
REITERATIONFacts
The Antecedents: The underlying dispute concerns Lot No. 2042, originally registered in the name of Feliciano Alveyra. The Municipality of Calapan acquired a one-half interest in this lot in satisfaction of a judgment against Alveyra. Subsequent litigation before the Court of Appeals (CA) and this Court resulted in the subdivision of Lot No. 2042 into Lot No. 2042-A, declared the property of Alveyra's heirs, and Lot No. 2042-B, declared the property of the Municipality of Calapan. The heirs of Alveyra subsequently sold their interest in Lot No. 2042-A to the respondent spouses Catly. Procedural History: The respondent Catlys, after obtaining new titles for the subdivided Lot No. 2042-A, filed an ejectment case and later a complaint for recovery of possession against the petitioners, alleging occupation of a portion of their property. In defense, the petitioners filed a complaint for the declaration of nullity of the Catlys' titles, claiming they were occupants of Lot No. 2042 since 1946 and lessees of the Municipality of Calapan, and that the Catlys' titles included portions of Lot No. 2042-B. The Regional Trial Court (RTC) dismissed the petitioners' complaint, finding they occupied portions of Lot No. 2042-A outside their leasehold rights over Lot No. 2042-B. The CA affirmed the RTC's dismissal, initially treating the petitioners' Rule 65 petition as an appeal and then ruling on the merits that the petitioners lacked a cause of action and were not real parties in interest. The Petition: The petitioners seek reversal of the CA's decision and resolution through a petition for certiorari under Rule 65 of the Rules of Court. They argue that the CA erred in dismissing their complaint for annulment of title and reiterate their claims of vested rights being impaired by the Catlys' titles. The petitioners contend they have sufficient interest to seek the annulment of the respondent Catlys' titles. The Supreme Court, however, finds that the petitioners have twice erroneously availed of the remedy of certiorari, as their grievances pertain to errors of judgment, not jurisdiction, and that they are not the real parties in interest to assail the titles concerning Lot No. 2042-A.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari filed by the petitioners. Whether the petitioners are the real parties in interest with sufficient legal standing to file an action for the annulment of the respondent Catlys' titles; and whether the petitioners have a valid cause of action against the respondent Catlys.
Ruling
The Supreme Court dismissed the petition for certiorari. It affirmed the decision of the Court of Appeals, which in turn affirmed the Regional Trial Court's dismissal of the complaint for declaration of nullity of titles.
Ratio Decidendi
On the propriety of the remedy: The Court reiterated that a petition for certiorari under Rule 65 is a special civil action that lies only when a tribunal, board, or officer exercising judicial, quasi-judicial, or ministerial functions has acted without or in excess of its jurisdiction, or with grave abuse of discretion amounting to lack of jurisdiction. It is not a remedy for correcting errors of judgment, which are errors of law or fact that do not affect the jurisdiction of the court. The petitioners' claim that the lower courts' findings were speculative and based on a misapprehension of facts constituted an attack on the correctness of the decisions, which are errors of judgment, not jurisdiction. Therefore, the proper remedy should have been an appeal under Rule 41 from the RTC's dismissal order and a petition for review on certiorari under Rule 45 from the CA's decision, not a petition for certiorari under Rule 65. The Court noted that the petitioners had twice availed of the wrong remedy, first before the CA and then before the Supreme Court. On the issue of real party in interest and cause of action: The Court affirmed the CA's ruling that the petitioners were not the real parties in interest and had no cause of action. The petitioners sought to annul the titles covering Lot No. 2042-A, which they admitted belonged to the respondent Catlys. Their claim of vested rights was based on their alleged lease agreement with the Municipality of Calapan over Lot No. 2042-B. The Court found that the petitioners were occupying portions of Lot No. 2042-A, which were outside the area covered by the Municipality's title (Lot No. 2042-B). Therefore, any alleged impairment of their rights as lessees of Lot No. 2042-B would not be affected by the titles issued to the respondent Catlys for Lot No. 2042-A. The Court emphasized that a real party in interest is one who stands to be benefited or injured by the judgment, and the petitioners' interest was not personal but rather an assertion of rights belonging to the Municipality of Calapan. As mere lessees, they lacked the material interest to assail the titles of the respondent Catlys. The Court cited Section 2, Rule 3 of the Rules of Court, which mandates that every action must be prosecuted in the name of the real party in interest, and that failure to do so is a ground for dismissal for lack of cause of action.
Main Doctrine
A petition for certiorari under Rule 65 of the Rules of Court is intended to correct only errors of jurisdiction, not errors of judgment. Errors of judgment are correctible by an ordinary appeal under Rule 41 or a petition for review on certiorari under Rule 45. Furthermore, an action for annulment of title must be instituted by the real party in interest, who is the party who stands to be benefited or injured by the judgment in the suit.