Pacheco v. Reyes
REITERATIONFacts
The Antecedents: Respondent Jimmy F. Reyes is the lawful possessor of a lot located at No. 39 Visayas Street, Payatas, Quezon City, which he acquired in 2004. Petitioner Caridad Pacheco and her late husband, Ramon Pacheco, Sr., entered into a contract of lease with Reyes for this property in 2012, agreeing to a monthly rental of PHP 6,000.00. Beginning April 1, 2017, the Pachecos failed to pay the agreed rentals. Despite multiple demands to pay and vacate, they remained in possession of the premises. Procedural History: After the Pachecos allegedly ignored a complaint filed before the Lupon ng Tagapamayapa, a Certificate to File Action was issued. Subsequently, Reyes filed a complaint for Unlawful Detainer and Damages against the Pachecos. The Metropolitan Trial Court (MeTC) ruled in favor of Reyes, ordering the Pachecos to vacate, pay accrued rentals, attorney's fees, and costs. The Regional Trial Court (RTC), on appeal, affirmed the MeTC's decision. The Pachecos then elevated the case to the Court of Appeals (CA) via a Petition for Certiorari. The CA dismissed the petition outright, citing the improper remedy and procedural deficiencies, and later denied their motion for reconsideration. The Petition: Petitioner Caridad Pacheco filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's dismissal of her petition. She argued that the CA erred in dismissing her petition, claiming substantial compliance with the required verification and certification against forum shopping, and asserting that a Rule 42 appeal was no longer available due to the finality of the RTC decision under expedited procedures. The Supreme Court denied the petition, finding no reversible error in the CA's dismissal, emphasizing the procedural infirmities and the petitioner's failure to avail of the correct and timely remedies.
Issue(s)
Whether the Court of Appeals erred in dismissing the Petition for Certiorari. Whether the petitioner substantially complied with the procedural requirements for filing a petition with the Court of Appeals. Whether the Rules on Expedited Procedures (A.M. No. 08-8-7-SC) were applicable to the case.
Ruling
The Supreme Court denied the Petition for Review on Certiorari and affirmed the Resolutions of the Court of Appeals. The Court found no reversible error in the CA's dismissal of the petition.
Ratio Decidendi
On the propriety of the remedy: The Court held that the CA correctly dismissed the Petition for Certiorari because the proper remedy to assail an RTC decision in its appellate jurisdiction is a Petition for Review under Rule 42 of the Rules of Court, not a Petition for Certiorari under Rule 65. A petition for certiorari is an original action for errors of jurisdiction or grave abuse of discretion, and cannot be a substitute for a lost appeal. The availability of an appeal under Rule 42 rendered the resort to certiorari improper. The Court emphasized that the right to appeal is a statutory privilege, not a natural right, and must be exercised in accordance with law. Procedural rules are designed to facilitate the adjudication of cases and should be faithfully complied with. The RTC Decision, having been received by petitioner's counsel on April 28, 2022, and with the motion for reconsideration denied on March 2, 2022, became final and executory by operation of law when the 15-day reglementary period for filing a Rule 42 petition lapsed without such a petition being filed. Thus, the RTC decision was immutable and unalterable. On procedural infirmities: The Court found that the CA's dismissal was also warranted due to several procedural infirmities in the petitioner's Petition for Certiorari. These included the lack of a proper verification and a certification against forum shopping, and the failure to attach essential pleadings. The Court reiterated that while defects in verification may sometimes be cured by substantial compliance, a defective certification against forum shopping is generally not curable, unless there are compelling reasons or special circumstances. The Court found that the petitioner's alleged subsequent submissions did not constitute substantial compliance. On the applicability of A.M. No. 08-8-7-SC: The Court clarified that the Rules on Expedited Procedures (A.M. No. 08-8-7-SC), which took effect on April 11, 2022, has prospective application only. Since the MeTC case was filed on April 3, 2019, and decided on September 21, 2020, and the RTC affirmed the ruling on July 9, 2021, the said rules were not applicable to the case. Rule V of A.M. No. 08-8-7-SC explicitly states that it applies only to cases filed from its date of effectivity, and pending cases shall be decided based on rules applicable at the time of filing.
Main Doctrine
The Court of Appeals correctly dismissed a Petition for Certiorari filed assailing an RTC decision in its appellate jurisdiction, as the proper remedy was a Petition for Review under Rule 42. Furthermore, the petition was dismissed for failure to comply with procedural requirements such as verification and certification against forum shopping, and for being filed beyond the reglementary period, rendering the RTC decision final and unappealable.