Merino v. Alarcon
REITERATIONFacts
The Antecedents: Juan Merino filed a complaint for ejectment against Cirilo Alarcon in the City Court of Manila. The Court of First Instance (CFI) tried the case de novo and ordered Alarcon to vacate the premises. Procedural History: Alarcon filed a notice of appeal to the Court of Appeals (CA), alleging that the CFI's findings of fact were not supported by substantial evidence. The CFI initially approved the Record on Appeal but later recalled and cancelled it, deeming the decision final and unappealable to the CA under existing laws, and ordered the issuance of a writ of execution. The CA set aside the CFI's orders and directed the elevation of the Record on Appeal. The Petition: Merino filed a petition with the Supreme Court, seeking to declare that Alarcon may no longer appeal by ordinary appeal as the decision had become final under Republic Act (RA) No. 6031.
Issue(s)
Whether an ordinary appeal to review the facts was available to Alarcon. Whether Judge Agcaoili acted properly when he set aside the Record on Appeal and ordered the execution of the decision.
Ruling
The judgment of the Court of Appeals is set aside, and the orders of the Court of First Instance of Manila dated April 12, 1973, and May 30, 1973, are reinstated. The writ of execution is ordered to be issued.
Ratio Decidendi
On the issue of appealability of CFI decisions in appealed cases from inferior courts: The Court held that under Section 45 of the Judiciary Act of 1948, as amended by Republic Act No. 6031, decisions of Courts of First Instance (now Regional Trial Courts) in the exercise of their appellate jurisdiction over cases triable exclusively by inferior courts are final. This means that an ordinary appeal by record on appeal is no longer available for such decisions. The finality applies regardless of whether the CFI decision affirms in full, reverses, or modifies the judgment of the inferior court. The Court explicitly abandoned the doctrine laid down in Mota v. Court of Appeals which had previously suggested a distinction based on whether the CFI affirmed the lower court's judgment in full. The Court emphasized that the purpose of RA 6031 was to provide finality to CFI decisions in these cases to ease appellate court backlogs and discourage dilatory appeals. The Court cited Gutierrez v. Magat which held that Section 45 of the Judiciary Law as amended by RA 6031 does not allow an appeal by record on appeal from the decision of the Court of First Instance in an appealed case falling within the exclusive original jurisdiction of the municipal or city court. On the issue of the propriety of Judge Agcaoili's actions: Therefore, Judge Agcaoili acted correctly in recalling and cancelling the Record on Appeal and ordering the execution of the decision, as the case was no longer appealable to the Court of Appeals via ordinary appeal.
Main Doctrine
Decisions of Courts of First Instance (now Regional Trial Courts) in the exercise of their appellate jurisdiction over cases triable exclusively by inferior courts are final and not appealable by ordinary appeal or record on appeal, but may be reviewed by petition for review on certiorari.