Alfiler v. Cayabyab
REITERATIONFacts
The Antecedents: This case originates from a dispute over a parcel of land at 186 Pajo Street, Quezon City. In 1985, the original owner, Quintin Santiago, Jr., entered into an amicable settlement with Linglingay Corpuz (mother of petitioner Lilah Gail Corpuz Alfiler) and others, agreeing to sell the property for P146,000.00. Linglingay, et al. made partial payments totaling P72,425.00 but did not complete the purchase. Quintin Santiago, Jr. passed away in 1997. In 2010, respondents, the Spouses John and Geraldine Cayabyab, filed an ejectment case against petitioner and others, claiming ownership based on a Deed of Absolute Sale purportedly executed by Quintin through his attorney-in-fact, Norman Santiago, in August 1997. Procedural History: The Spouses Cayabyab filed an ejectment complaint before the Metropolitan Trial Court (MeTC), which ruled in their favor on January 3, 2011, ordering the defendants to vacate the premises. This decision was affirmed in toto by the Regional Trial Court (RTC) on January 9, 2013. Petitioner Lilah Gail Corpuz Alfiler, along with Meda Delza Armamento, appealed to the RTC. After the RTC denied their motion for reconsideration, petitioner filed a Petition for Certiorari with the Court of Appeals (CA) on November 22, 2013, assailing the RTC's decision. The CA dismissed this petition on December 13, 2013, and subsequently denied the motion for reconsideration on February 17, 2015, holding that certiorari was the wrong mode of appeal. The Petition: Petitioner Lilah Gail Corpuz Alfiler filed the present Petition for Certiorari under Rule 45 of the Rules of Court, seeking to reverse the CA's dismissal. Petitioner argues that the CA erred in dismissing her certiorari petition, contending that the Deed of Absolute Sale is void because it was executed after the seller, Quintin Santiago, Jr., had already died, and that the alleged attorney-in-fact lacked written authority. Furthermore, petitioner asserts that the MeTC lacked jurisdiction over the ejectment case as it was filed more than one year after the alleged dispossession. Petitioner seeks a liberal application of the rules in the interest of substantial justice to address these substantive issues.
Issue(s)
Whether the Court of Appeals erred in dismissing the Petition for Certiorari on the ground of being the wrong mode of appeal. Whether the Deed of Absolute Sale (DOAS) is null and void due to the death of the principal and lack of a valid Special Power of Attorney. Whether the agency relationship was extinguished by the death of the principal. Whether the Metropolitan Trial Court (MeTC) had jurisdiction over the ejectment case.
Ruling
The petition is GRANTED. The Resolutions of the Court of Appeals are REVERSED and SET ASIDE. The complaint filed before the Metropolitan Trial Court is DISMISSED.
Ratio Decidendi
On the wrong mode of appeal: The Supreme Court acknowledged that petitioner availed of the wrong remedy by filing a petition for certiorari instead of a petition for review under Rule 42. A petition for certiorari is only available when there is no appeal, or any plain, speedy, and adequate remedy in the ordinary course of law. Since an appeal was available, certiorari could not be a substitute for a lost appeal due to negligence. However, the Court found exceptions to the strict application of rules, citing that the broader interests of justice required addressing the patent errors in the assailed decisions, especially since petitioner stood to lose a family home. The Court emphasized that if strict adherence to rules results in a miscarriage of justice, the rules may be relaxed in favor of substantial justice. On the Deed of Absolute Sale (DOAS) and agency: The Court found severe legal infirmities in the respondents' claim of ownership. The DOAS was executed on August 20, 1997, but the seller, Quintin Santiago, Jr., had already died on March 12, 1997, five months prior. The death of a principal terminates contractual capacity, rendering any act of the agent thereafter void ab initio. Furthermore, respondents failed to present the mandatory written Special Power of Attorney (SPA) required by Article 1874 of the Civil Code for the sale of land through an agent. Without a written SPA and with the seller already deceased, the DOAS is void ab initio, and respondents acquired no rights or interest over the property. On the extinguishment of agency: The Court reiterated that agency is extinguished by the death of the principal, as provided in Article 1919(3) of the Civil Code. Any act of an agent after the death of the principal is void ab initio, unless specific exceptions under Articles 1930 or 1931 apply, neither of which were alleged or applicable in this case. The Court also noted that merely referring to an SPA in a deed of sale is insufficient; it must be offered in evidence. The failure to present the SPA gives rise to the presumption that no such written authority existed. On the jurisdiction of the MeTC: The Court found that respondents failed to establish their de facto right of possession because their claim of ownership, anchored on the void DOAS, was unsubstantiated. In ejectment cases, the plaintiff bears the burden of proof to establish by preponderance of evidence their right of possession. Since the DOAS was void ab initio, respondents did not acquire any right over the property, and thus, their cause of action for unlawful detainer was not proven. Consequently, the complaint should be dismissed for insufficiency of factual or legal basis.
Main Doctrine
A petition for certiorari under Rule 65 is not a substitute for an appeal under Rule 42 when the latter remedy is available but was lost through fault or negligence. However, the strict application of procedural rules may be relaxed in the interest of substantial justice, especially when the lower courts' decisions are infirm for failing to clearly and distinctly state the facts and the law on which they are based, in contravention of the constitutional mandate.