Guzman v. Guzman
REITERATIONFacts
The Antecedents: Petitioner Isabel N. Guzman filed an ejectment case against her children, respondents Aniano N. Guzman and Primitiva G. Montealto, for occupying a parcel of land she co-owned. Guzman alleged that the respondents occupied the land by tolerance and failed to vacate after a written demand and unsuccessful barangay conciliation. The respondents countered that Guzman had transferred her property rights, except for usufruct, to them and that Guzman was engaged in forum shopping due to a pending case regarding adverse claim cancellation. Procedural History: The Municipal Trial Court (MTC) ruled in favor of Guzman, finding her to be the lawful owner with a right to possession and ordering the respondents to vacate and pay rentals and damages. The respondents appealed to the Regional Trial Court (RTC), which, while acknowledging the MTC's jurisdiction and Guzman's valid cause of action, reversed the MTC's decision. The RTC cited Guzman's transfer of rights to the respondents, which could not be unilaterally revoked, and her failure to allege earnest efforts at compromise. Guzman filed three motions for reconsideration with the RTC, all of which were denied. Subsequently, she filed a petition for certiorari with the Court of Appeals (CA), which dismissed it, holding that a petition for review under Rule 42 was the proper remedy and that Guzman had lost her right to appeal by filing a prohibited second motion for reconsideration. The Petition: Petitioner Isabel N. Guzman filed the present petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's decision and resolution. She argues that the CA erred in dismissing her petition for certiorari, contending that the RTC judge acted with grave abuse of discretion by deciding on issues not raised on appeal and by denying her motion for reconsideration on a technicality. Guzman further asserts that the CA's finding of co-ownership lacks factual and legal basis. The respondents maintain that the proper remedy was a Rule 42 petition for review and that certiorari cannot substitute for a lost appeal.
Issue(s)
Whether the Court of Appeals committed a reversible error in dismissing the petitioner's petition for certiorari regarding the propriety of the remedy and the loss of the right to appeal. Whether the RTC committed grave abuse of discretion in its rulings and in denying the motions for reconsideration. Whether the CA erred in its finding of co-ownership, considering the nature of ejectment cases and the provisional determination of ownership.
Ruling
The Supreme Court denied the petition for review on certiorari, affirming the decision of the Court of Appeals. The Court held that the petitioner availed of the wrong remedy and that the RTC decision had become final and executory.
Ratio Decidendi
On the propriety of the remedy and loss of right to appeal: The Court held that the petitioner's resort to a Rule 65 petition for certiorari was misplaced, as a Rule 42 petition for review was the proper remedy. The filing of a prohibited second motion for reconsideration caused the petitioner to lose her right to appeal, rendering the RTC decision final and executory. Certiorari cannot substitute for a lost appeal due to the petitioner's negligence. The remedies of appeal and certiorari are mutually exclusive. On grave abuse of discretion: Even assuming the petition could be properly filed under Rule 65, the Court found no grave abuse of discretion on the part of the RTC. Certiorari is restricted to errors of jurisdiction and grave abuse of discretion, not mere errors of judgment. The imputed errors pertained to the RTC's appreciation of facts and application of law, not its jurisdiction. The RTC acted within its jurisdiction in considering the transfer of rights, and the strict enforcement of the notice of hearing requirement was upheld as an integral component of procedural due process. On the nature of ejectment cases and provisional determination of ownership: The Court reiterated that ejectment cases are summary proceedings to protect actual possession. Title is not the primary issue, and any ruling on ownership is provisional, solely for determining possession de facto. Therefore, any ruling on the validity of the petitioner's transfer of rights was provisional and should be resolved in a proper proceeding.
Main Doctrine
A Rule 65 petition for certiorari is not a substitute for a lost appeal, especially when the loss is occasioned by the petitioner's own negligence or error in choosing the remedy, such as filing a prohibited second motion for reconsideration which renders the decision final and executory.