Almendras v. South Davao Development
REITERATIONFacts
The Antecedents: Petitioner Alexis C. Almendras filed an Amended Complaint seeking to annul a Deed of Sale (DOS) executed by respondents Caridad C. Almendras, Rolando C. Sanchez, and Leonardo Dalwampo over a parcel of unregistered land. Petitioner alleged ownership and possession since 1978 until dispossession by respondent South Davao Development Company, Inc. (SODACO) in 1994, claiming Caridad sold the property to Rolando, a purported dummy of SODACO. Procedural History: Respondent Rolando C. Sanchez filed a Request for Admission, seeking to establish the genuineness of court resolutions and orders related to a guardianship proceeding for Alejandro D. Almendras, Sr., and the validity of a Deed of Sale over the subject property in his favor. Petitioner failed to file a sworn statement denying the matters therein. Consequently, Rolando filed a Motion for Summary Judgment, arguing no genuine issue of material fact existed. The Regional Trial Court (RTC), Branch 20, Digos, Davao del Sur, in its March 28, 2011 Order, granted partial summary judgment, dismissing the complaint against Rolando and setting the issue of damages for hearing. The RTC found that petitioner was duly served with the motion and that his failure to respond to the Request for Admission constituted an implied admission of the matters therein, rendering the complaint without cause of action. Petitioner's Motion for Reconsideration was denied, and SODACO's motion was granted, leading to the dismissal of the complaint against all defendants. The RTC's Orders dated March 28, 2011, and August 9, 2011, were assailed. The Petition: Petitioner filed a Petition for Review on Certiorari, alleging grave abuse of discretion on the part of the RTC. He questioned the RTC's findings regarding service of the motion and the implied admission from his failure to respond to the Request for Admission.
Issue(s)
Whether the trial court could dismiss the petitioner's complaint motu proprio for failure to file objections to a Request for Admission, which was allegedly only furnished to his counsel. Whether the trial court could interpret the petitioner's failure to file objections to the Request for Admission as an implied admission of the matters specified therein, and whether summary judgment was applicable. Whether the petitioner properly observed the hierarchy of courts in filing the appeal.
Ruling
The Supreme Court denied the Petition for Review on Certiorari. It held that the petition was filed through the wrong mode of appeal, as it raised factual issues that should have been elevated to the Court of Appeals via ordinary appeal. The Court found that the issues presented, particularly regarding the service of court processes and the veracity of factual claims, were matters of fact, not of law, and thus beyond the scope of a Rule 45 petition. The Court also noted that the petitioner failed to exhaust available remedies before filing the case directly with the Supreme Court.
Ratio Decidendi
On the propriety of the mode of appeal: The Court reiterated that a petition for review on certiorari under Rule 45 is limited to questions of law. Factual issues, such as whether a party was properly served with court processes or whether a statement is deemed admitted due to non-response, fall outside the purview of Rule 45. The Court cited Nazareno v. City of Dumaguete to distinguish between a petition for review (Rule 45) and a petition for certiorari (Rule 65), emphasizing that the former addresses errors of judgment, while the latter corrects errors of jurisdiction, including grave abuse of discretion. The Court found that the petitioner's claim of improper service of the Request for Admission and the RTC's alleged error in deeming it admitted were factual disputes that necessitated an examination of evidence, which is not permissible in a Rule 45 petition. The Court also pointed out that the petitioner failed to raise the issue of service of the Motion for Summary Judgment, focusing instead on the Request for Admission. On the implied admission and summary judgment: The Court noted that the RTC had already ruled that the petitioner was duly served with the Request for Admission and that his failure to respond led to an implied admission of the facts stated therein. This ruling, based on the evidence and the rules of procedure, was a factual determination. The applicability of summary judgment, as argued by respondent Sanchez, hinges on the absence of a genuine issue as to any material fact. The RTC's finding that the petitioner's failure to respond to the Request for Admission created such an admission was a factual conclusion that supported the grant of summary judgment. The Court found that addressing the petitioner's arguments would require a review of the evidence presented before the RTC, which is beyond the scope of a petition for review on certiorari. On the hierarchy of courts: The Court emphasized that direct resort to the Supreme Court from the Regional Trial Court, bypassing the Court of Appeals, is generally not permitted. The proper mode of appeal from an RTC decision in the exercise of its original jurisdiction is an ordinary appeal under Rule 41 to the Court of Appeals, which can consider questions of fact, law, or mixed questions. The Court cited Five Star Marketing Company, Inc. v. Booc to clarify the different modes of appeal. By filing the petition directly with the Supreme Court, the petitioner circumvented the established hierarchy of courts and failed to avail of the appropriate remedy, which would have been an appeal to the CA. This procedural misstep alone warranted the dismissal of the petition.
Main Doctrine
A petition for review on certiorari under Rule 45 of the Rules of Court is limited to questions of law, and issues involving the veracity of factual claims, such as the receipt of court processes, are generally outside its scope. Furthermore, direct resort to the Supreme Court from the Regional Trial Court, bypassing the Court of Appeals, is generally not allowed unless specific exceptions apply.