Nacionales v. Solde-Annogui
REITERATIONFacts
The Antecedents: PERA Multipurpose Cooperative (respondent) filed a small claims action against David Nacionales (petitioner) for collection of a sum of money and damages. Respondent alleged that petitioner obtained a loan of P67,700.00 on July 13, 2017, payable within 24 months at 24% per annum interest. Petitioner defaulted, and as of March 29, 2019, his outstanding obligation, including interest, penalty, and attorney's fees, amounted to P49,436.46. Respondent sent a demand letter, which was unheeded. Procedural History: Petitioner failed to submit a response despite receipt of the summons and statement of claim. On July 3, 2019, both parties appeared in court but failed to reach a settlement. The Municipal Circuit Trial Court (MCTC) of Nabunturan-Mawab-Montevista, presided over by Judge Leah Garnet G. Solde-Annogui, partly granted the respondent's claim. The MCTC ordered petitioner to pay P36,647.00 as principal and P7,447.00 as interest, plus 24% per annum interest from finality until fully paid, and costs of suit. The Petition: Aggrieved, petitioner filed a Petition for Certiorari and Mandamus with Prayer for Damages before the Supreme Court, seeking to nullify the MCTC decision. Petitioner argued that the repayment schedule violated the Truth in Lending Act, that the deduction of prepaid interest was a fraudulent scheme constituting Syndicated Estafa, that he was denied due process as the judge was allegedly not present during the hearing, and that the 24% interest imposed after finality of judgment was incorrect.
Issue(s)
Whether or not the computation in the repayment schedule of the respondent-plaintiff violates the Truth in Lending Act. Whether or not the public respondent did not conduct a hearing in violation of the Small Claims Rules, and denied petitioner-defendant's constitutional right to due process. Whether or not the 24% interest imposed by the public respondent after finality of judgment is correct.
Ruling
The petition is DISMISSED for violation of the policy on the hierarchy of courts. Even if the policy were disregarded, the petitioner would still not be entitled to the extraordinary writ of certiorari.
Ratio Decidendi
On the issue of the alleged violation of the Truth in Lending Act: The Court noted that the petitioner's claims regarding the computation of interest fall under evidentiary matters. The Supreme Court is not a trier of facts and cannot re-examine the evidence presented in the lower court. A petition for certiorari under Rule 65 is grounded on errors in jurisdiction, not on errors in the appreciation of evidence or the merits of the case. The petitioner failed to establish any jurisdictional error in the MCTC's decision concerning the loan computation or the alleged violation of the Truth in Lending Act. On the issue of the alleged denial of due process and lack of hearing: The respondent judge denied the petitioner's claim of denial of due process. She asserted her presence on July 3, 2019, and stated that the petitioner walked out after being advised to enter her chambers, which was considered a non-appearance. The Court found that the petitioner failed to establish that the MCTC decision was tainted with jurisdictional errors amounting to a denial of due process. The petitioner's assertions were primarily factual and evidentiary, which are not proper grounds for a petition for certiorari. The Court reiterated that certiorari is available only when there is no appeal or any other plain, speedy, and adequate remedy, and it is grounded on errors in jurisdiction, not on the merits of the case. On the issue of the imposition of 24% interest after finality of judgment: The petitioner questioned the imposition of 24% per annum interest on the awarded amount after the finality of the judgment. The Court noted that the promissory note itself stipulated an interest rate of 24% per annum. While the MCTC awarded principal and interest, the imposition of interest on the awarded amount after finality is a matter that should have been raised through proper appeal or a motion for reconsideration, not through a petition for certiorari based on jurisdictional error. The petitioner's argument on this point also delves into the merits of the case and the interpretation of the contract, which are not within the scope of a Rule 65 petition. The Court found no jurisdictional error in the MCTC's decision regarding the interest rate.
Main Doctrine
A petition for certiorari against a decision of a Municipal Circuit Trial Court (MCTC) in a small claims case should be filed with the Regional Trial Court (RTC), not directly with the Supreme Court, absent any special and compelling reason. Direct filing with the Supreme Court violates the policy on the hierarchy of courts.