Medina v. Lozada
REITERATIONFacts
The Antecedents: This case stems from a dispute over land ownership and possession. The petitioners, heirs and successors-in-interest of the late Clemente Dalandan, claim ownership over several parcels of land, including salt beds in Las Piñas City, which they assert were inherited. They allege that the respondents, Spouses Nicomedes and Brigida Lozada, obtained a title (OCT 0-78) for a significant portion of this land based on a prior court decision, and subsequently, the respondents' tax declaration cancelled Clemente Dalandan's. The petitioners filed a complaint for quieting of title and reconveyance, asserting their entitlement to a specific portion of the land and demanding reconveyance of any excess fraudulently encroached upon by the respondents. Procedural History: The petitioners' initial complaint, Civil Case No. 07-0041, was filed before the Regional Trial Court (RTC) of Las Piñas City, Branch 201. The respondents filed a Motion to Dismiss, citing grounds such as res judicata, lack of cause of action, lack of jurisdiction, forum shopping, and prescription. The RTC, in an Order dated July 27, 2007, dismissed the case on the ground of res judicata, finding that the four requisites for the doctrine were met, referencing a 1989 decision confirming the respondents' title. The RTC subsequently denied the petitioners' Motion for Reconsideration in an Order dated December 28, 2007. Aggrieved, the petitioners filed a petition for certiorari with the Court of Appeals (CA), which dismissed their petition, holding that the RTC's dismissal order was a final order and the proper remedy was an appeal under Rule 41, not a special civil action for certiorari. The CA further denied the petitioners' motion for reconsideration. The Petition: The petitioners are now before the Supreme Court via a petition for review on certiorari under Rule 45 of the Rules of Court. They contend that the Court of Appeals erred in dismissing their petition for certiorari. Specifically, they argue that the RTC's dismissal order and the subsequent denial of their motion for reconsideration were interlocutory orders, not final judgments on the merits, and thus, certiorari was the appropriate remedy. The petitioners seek to overturn the CA's ruling, which affirmed the RTC's dismissal of their complaint on the grounds of res judicata and the procedural impropriety of their chosen remedy.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari under Rule 65. Whether the RTC Orders dismissing the case on the ground of res judicata and denying the motion for reconsideration were final or interlocutory.
Ruling
The Supreme Court denied the petition for review on certiorari, affirming the Decision and Resolution of the Court of Appeals. The Court held that the CA committed no reversible error.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in dismissing the petition for certiorari under Rule 65: The Court held that the CA did not err. Section 1, Rule 41 of the Rules of Court mandates that appeal is the remedy for a judgment or final order that completely disposes of a case. A petition for certiorari under Rule 65 is unavailable if there is an appeal or any plain, speedy, and adequate remedy in the ordinary course of law. The petitioners filed their Rule 65 certiorari petition before the CA after the reglementary period to appeal the RTC Order of dismissal had already lapsed. In fact, their certiorari petition was filed a day late. On the issue of whether the RTC Orders dismissing the case on the ground of res judicata and denying the motion for reconsideration were final or interlocutory: The Court affirmed the CA's ruling that the assailed Orders were final. An order or a judgment is deemed final when it finally disposes of a pending action, leaving nothing more to be done in the lower court. An order of dismissal, regardless of its correctness, is a final order because it terminates the proceedings and leaves nothing more for the lower court to do. Therefore, the proper remedy for the petitioners was to appeal the order of dismissal, not to file a special civil action for certiorari. The CA correctly pointed out that certiorari cannot be used as a substitute for a lost appeal, especially when the loss is due to the party's own negligence or error in choosing the remedy.
Main Doctrine
An order of dismissal, whether correct or not, is a final order that terminates the proceedings in the lower court, leaving nothing more to be done. Therefore, the proper remedy is appeal, not a special civil action for certiorari, as the latter cannot be used as a substitute for a lost appeal.