Polytechnic University v. National Development
REITERATIONFacts
The Antecedents: National Development Company (NDC) owned a ten-hectare property. NDC entered into lease contracts with Golden Horizon Realty Corporation (GHRC), granting GHRC an option to purchase the leased areas. GHRC sought to exercise its option, but NDC did not reply and instead attempted to dispose of the property to a third party. GHRC filed a complaint for specific performance and damages. Procedural History: - Presidential Memorandum Order No. 214 ordered the transfer of the NDC Compound to the National Government, which would then convey it to Polytechnic University of the Philippines (PUP). - The Regional Trial Court (RTC) ruled in favor of GHRC, upholding its right to purchase the leased areas and ordering PUP to reconvey the property to GHRC upon payment. - The Court of Appeals (CA) affirmed the RTC decision. - The Supreme Court (SC), in G.R. Nos. 183612 and 184260, affirmed the RTC decision with modification, increasing the purchase price per square meter. - The SC decision became final and executory. GHRC deposited the purchase price. - PUP filed a manifestation claiming entitlement to the purchase price instead of NDC. - The RTC issued an order directing the withdrawal of the purchase price, execution of a deed of conveyance, and delivery of owner's duplicate titles. - NDC and PUP sought reconsideration. - The RTC issued a resolution modifying its previous order, allowing NDC to withdraw the purchase price, directing NDC to deliver titles to PUP, directing the Register of Deeds to issue new titles in PUP's name (representing the National Government for transfer to GHRC), and ordering PUP to execute a deed of conveyance to GHRC. The RTC clarified that the subject properties were not transferred to the National Government due to pending litigation at the time of Memorandum Order No. 214. - PUP filed a petition for certiorari and prohibition with the CA, alleging grave abuse of discretion by the RTC. - The CA dismissed PUP's petition. - PUP's motion for reconsideration was denied. The Petition: PUP filed a petition for review on certiorari under Rule 45, seeking to reverse the CA's dismissal of its petition for certiorari and prohibition.
Issue(s)
Whether the appellate court erred on a question of law when it dismissed the petition for the imputed failure of PUP to file a motion for reconsideration of the trial court's resolution dated February 2, 2012. Whether the appellate court erred on a question of law when it upheld the trial court's order dated September 5, 2011 and resolution dated February 2, 2012.
Ruling
The petition is denied for lack of merit. The Court of Appeals did not err in dismissing the petition for certiorari and prohibition filed by the Polytechnic University of the Philippines.
Ratio Decidendi
On the issue of whether the appellate court erred on a question of law when it dismissed the petition for the imputed failure of PUP to file a motion for reconsideration of the trial court's resolution dated February 2, 2012: The Supreme Court clarified that the present petition seeks to review the CA's resolution of a Rule 65 petition. A petition for certiorari under Rule 65 is confined to questions of jurisdiction, specifically whether a tribunal acted without jurisdiction, in excess of jurisdiction, or with grave abuse of discretion amounting to lack of jurisdiction. The Court found that PUP failed to substantiate its imputation of grave abuse of discretion against the RTC. The CA correctly pointed out that the RTC's February 2, 2012 resolution merely sought to resolve the impossibility of complying with the reconveyance order, given that the property was not under PUP's name. The RTC's actions were aimed at implementing the final and executory decision of the Supreme Court, considering the factual circumstances of the property's status. On the issue of whether the appellate court erred on a question of law when it upheld the trial court's order dated September 5, 2011 and resolution dated February 2, 2012: The Supreme Court affirmed the CA's finding that the RTC committed no grave abuse of discretion. The RTC's February 2, 2012 resolution was a clarification of its September 5, 2011 order, aimed at settling the controversy and fully implementing the Supreme Court's final decision. The RTC correctly noted, based on the Memorandum of Agreement (MOA) between NDC and the National Government, that the subject properties were excluded from the transfer because they were subject to pending court litigation at the time. Consequently, these properties were never conveyed to the National Government, and thus never to PUP. The RTC's modification was a logical step to ensure the execution of the judgment, recognizing that PUP could not reconvey property it did not legally possess. The CA's affirmation of the RTC's actions was therefore proper, as the RTC acted within its jurisdiction to clarify and implement its own final judgment in light of supervening factual circumstances.
Main Doctrine
The Court of Appeals correctly dismissed the petition for certiorari and prohibition, finding that the Regional Trial Court did not commit grave abuse of discretion in issuing its assailed orders, as these orders merely clarified and implemented the final and executory decision of the Supreme Court, considering the factual circumstances that certain properties were excluded from the transfer to the National Government due to pending litigation.