Villamar-Sandoval v. Cailipan
REITERATIONFacts
The Antecedents: Petitioner Irene Villamar-Sandoval filed a complaint for damages against respondents, alleging that they maliciously filed a baseless libel case against her. This libel case stemmed from statements petitioner allegedly made during a homeowner's association meeting regarding respondent Jose Cailipan's criminal record for murder, slight physical injuries, and estafa. Petitioner claimed these statements were intended to damage Cailipan's reputation and facilitate his removal as president of the association. Procedural History: Respondents filed their answer one day late, which the Regional Trial Court (RTC) initially admitted. However, respondents' counsel subsequently failed to appear at the pre-trial conference and did not file a pre-trial brief. The RTC declared respondents in default on October 20, 2010, and denied their motion for reconsideration on November 10, 2010. The RTC then proceeded to receive petitioner's evidence ex parte. Respondents filed a petition for certiorari with the Court of Appeals (CA), arguing grave abuse of discretion by the RTC. Separately, respondents also filed a notice of appeal from the RTC's decision. The CA granted the certiorari petition, setting aside the RTC's default orders and remanding the case for reception of respondents' evidence. The Petition: The petitioner seeks review on certiorari of the CA's decision, arguing that the CA erred in setting aside the RTC's default orders. The core of the petitioner's argument before this Court is that the respondents' petition for certiorari before the CA was an improper remedy and had become moot and academic because respondents had already filed an ordinary appeal from the RTC's decision. Petitioner contends that appeal and certiorari are mutually exclusive remedies, and the filing of an appeal renders a pending certiorari petition superfluous and mandates its dismissal.
Issue(s)
Whether respondents' petition for certiorari was an improper remedy and/or had been rendered moot and academic by virtue of the RTC’s January 11, 2011 Decision. Whether the CA erred in setting aside the October 20, 2010 and November 10, 2010 RTC Orders.
Ruling
The petition is meritorious. The Supreme Court set aside the September 30, 2011 Decision and February 1, 2012 Resolution of the Court of Appeals, thereby reinstating the RTC's default orders. The Court held that the CA erred in granting the certiorari petition, which had become moot and academic due to the subsequent filing of an ordinary appeal.
Ratio Decidendi
On the issue of whether respondents' petition for certiorari was an improper remedy and/or had been rendered moot and academic by virtue of the RTC’s January 11, 2011 Decision: The Court ruled that the remedies of appeal and certiorari are mutually exclusive and cannot be availed of simultaneously or successively. The filing of an ordinary appeal under Rule 41 renders a pending petition for certiorari under Rule 65 superfluous and mandates its dismissal, as the latter requires the absence of an appeal. In this case, respondents filed a petition for certiorari on January 11, 2011, and subsequently filed a Notice of Appeal on January 22, 2011, after the RTC had rendered its decision on January 11, 2011. Although respondents received the RTC decision on January 24, 2011, the filing of the appeal on January 22, 2011, made the certiorari petition moot. The Court noted that respondents should have either withdrawn their certiorari petition and raised the alleged jurisdictional errors in their appeal, or at the very least, informed the CA of the RTC's decision and their filing of the appeal. Their failure to do so created a procedural impasse. The Court emphasized that a case becomes moot when no useful purpose can be served in passing upon its merits, and courts generally will not determine a moot question where no practical relief can be granted. Therefore, the CA's decision granting the certiorari petition on incidental matters was inappropriate given that a decision on the main case had already been rendered and could be elevated on appeal. On the issue of whether the CA erred in setting aside the October 20, 2010 and November 10, 2010 RTC Orders: The Court held that there was no cogent reason to further dwell on the issue of the RTC's grave abuse of discretion in issuing the default orders. As previously established, the CA erred in granting the certiorari petition, which had become moot and academic. Consequently, the matter of the validity of the default orders, including any alleged grave abuse of discretion by the RTC, may be properly ventilated on appeal. The Court's action in setting aside the CA's resolutions was intended to allow the CA division handling the appeal of the main case to appropriately pass upon the merits of the RTC's decision and all assailed irregularities in the proceedings, thereby avoiding the perpetuation of procedural errors.
Main Doctrine
A petition for certiorari under Rule 65 is rendered moot and academic and thus must be dismissed when an ordinary appeal under Rule 41 has already been filed, as the remedies are mutually exclusive and the appeal supersedes the certiorari petition.