Davao ACF Bus Lines, Inc. v. Ang
REITERATIONFacts
The Antecedents: This case originated from a criminal action, Criminal Case No. 99,282-E-2000, filed before the Municipal Trial Court in Cities (MTCC), Branch 5, Davao City, against Rodolfo Borja Tanio, the driver of a Daewoo Bus registered to Davao ACF Bus Lines, Inc. (ACF). Tanio was charged with reckless imprudence resulting in serious physical injuries for bumping a Mitsubishi sedan, causing damage to the vehicle and inflicting serious physical injuries upon its passenger, Rogelio Ang. The MTCC convicted Tanio and awarded damages to Ang, including P500,000.00 in nominal damages, P250,000.00 in moral damages, P100,000.00 in exemplary damages, and P50,000.00 in attorney's fees. This judgment became final and executory as no appeal was filed. Procedural History: Following the finality of the MTCC's judgment, a writ of execution was issued against Tanio, but it was returned unsatisfied due to his alleged lack of properties. Consequently, upon motion, the MTCC issued a writ of execution against ACF as Tanio's employer. ACF filed a Motion to Recall and/or Quash the Writ of Execution, which the MTCC denied in an Order dated March 21, 2007, but held the implementation of the writ in abeyance pending determination of the requisites for subsidiary liability under Article 103 of the Revised Penal Code. ACF's motion for reconsideration was also denied. ACF then filed a Petition for Review on Certiorari under Rule 65 with the Regional Trial Court (RTC) of Davao City, Branch 16, seeking to nullify the MTCC's Orders. The RTC denied ACF's petition, directing the MTCC to proceed with the hearing to determine subsidiary liability. ACF's subsequent motion for reconsideration was denied, and it filed a Notice of Appeal. The Court of Appeals (CA) affirmed the RTC's decision, denying ACF's appeal. ACF's motion for reconsideration with the CA was also denied. The Petition: Before the Supreme Court, ACF filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the Decision and Resolution of the CA. ACF argued that the MTCC committed grave abuse of discretion in ordering the execution of judgment against it, primarily contending that the MTCC's original judgment was void and that the aggregate amount of damages awarded was beyond the MTCC's jurisdiction. The Supreme Court denied the petition, holding that the MTCC did not commit grave abuse of discretion as it merely ordered a hearing to determine subsidiary liability and did not yet implement the writ of execution. The Court also emphasized that errors of judgment are not correctible by certiorari, that the original judgment was final and executory and not void, and that jurisdiction is determined by the allegations in the complaint, not the amount ultimately awarded.
Issue(s)
Whether the Court of Appeals erred in affirming the Regional Trial Court's holding that the Municipal Trial Court in Cities did not commit grave abuse of discretion amounting to lack or excess of jurisdiction in issuing its Order denying ACF's Motion to Recall and/or Quash The Writ of Execution and ordering the conduct of a hearing to determine whether or not ACF should be held subsidiarily liable under Article 103 of the Revised Penal Code for the civil liability ex delicto of its employee, accused Tanio. Whether the MTCC's judgment awarding damages was void, thereby divesting it of jurisdiction to order execution against ACF; specifically, whether the judgment was assailable via certiorari, whether it violated the doctrine of immutability of judgments, and whether the MTCC exceeded its jurisdiction over the subject matter.
Ruling
The Supreme Court denied the petition and affirmed the Decision and Resolution of the Court of Appeals. The Court held that the MTCC did not commit grave abuse of discretion and that the petition for certiorari was an improper remedy.
Ratio Decidendi
On the propriety of Certiorari and Grave Abuse of Discretion: The Court reiterated that certiorari is a remedy designed for the correction of errors of jurisdiction, not errors of judgment. An error committed while exercising jurisdiction does not deprive the court of that jurisdiction. The primary argument of ACF centered on the supposed erroneous award of damages, which pertains to mistakes of law, not of jurisdiction, and thus beyond the ambit of certiorari. Furthermore, the MTCC's Order dated March 21, 2007, did not order the execution against ACF but explicitly held its implementation in abeyance pending the determination of the requisites for subsidiary liability under Article 103 of the Revised Penal Code. This action of holding the execution in abeyance and ordering a hearing to determine subsidiary liability cannot be considered grave abuse of discretion. On the validity of the MTCC's judgment and jurisdiction: ACF's attempt to assail the award of damages made by the MTCC in its Judgment dated December 27, 2005, which was not appealed, constitutes an attack against a final and executory judgment, violating the doctrine of immutability of judgments. Once a judgment attains finality, it becomes immutable and unalterable, even if it is perceived to be erroneous, as long as the court rendering it had jurisdiction. A mere erroneous judgment is not a void judgment if the court had jurisdiction. Furthermore, ACF's argument that the MTCC was divested of jurisdiction because the aggregate amount of damages exceeded its jurisdictional limit was rejected. The Court emphasized that jurisdiction over the subject matter is determined by the allegations in the complaint, not by the amount ultimately substantiated and awarded. Therefore, even if the awarded damages were substantial, it did not divest the MTCC of its jurisdiction, especially since this argument was raised for the first time on appeal and was factually incorrect regarding the MTCC's actual order.
Main Doctrine
A petition for certiorari under Rule 65 is not the proper remedy to correct errors of judgment, but only errors of jurisdiction. An order holding the implementation of a writ of execution in abeyance pending determination of subsidiary liability under Article 103 of the Revised Penal Code does not constitute grave abuse of discretion, as it merely seeks to ascertain the existence of the requisites for such liability.