Indico v. Parcon
REITERATIONFacts
The Antecedents: The underlying dispute involved an action for forcible entry and detainer, initiated before the justice of the peace of Janiuay, Iloilo. Procedural History: The petitioner, Pablo Indico, first filed an application for a writ of certiorari in the Court of First Instance of Iloilo, seeking to set aside the decision and order of execution issued by the justice of the peace. This initial petition was denied. The Petition: Subsequently, Indico filed the present petition in the Supreme Court, substantially reproducing the dismissed petition and adding the Judge of the First Instance, Honorable F. Imperial Reyes, as a respondent. The petition seeks certiorari to review both the justice of the peace's and the Judge of First Instance's decisions, arguing alleged lack or excess of jurisdiction. The Supreme Court found the petition to be res judicata regarding the justice of the peace's actions and that certiorari was not the proper remedy against the Judge of First Instance's decision, as appeal would be the appropriate redress.
Issue(s)
Whether the Supreme Court may review by certiorari the decision and order of execution of a justice of the peace after a prior petition for the same relief was denied by the Court of First Instance. Whether the decision of the Court of First Instance denying a petition for certiorari can be reviewed by another petition for certiorari.
Ruling
The petition is dismissed with costs.
Ratio Decidendi
On Issue 1: The Supreme Court held that the decision and order of execution of the justice of the peace could not be reviewed by certiorari after a prior petition seeking the same relief had been dismissed. This situation falls squarely under the doctrine of res judicata, meaning the matter has already been judged and cannot be relitigated. The petitioner had already invoked the jurisdiction of the Court of First Instance, and its dismissal of the petition meant that the issues presented were deemed resolved or could not be further pursued through the same procedural vehicle. On Issue 2: The Court further clarified that certiorari does not lie against the decision of the Court of First Instance in this context. Appeal is the appropriate legal remedy against a decision of a Court of First Instance. Certiorari is an extraordinary remedy and is not a substitute for appeal unless it is clearly shown that appeal does not provide an adequate and complete remedy. To allow repeated petitions for certiorari against decisions of successive courts would create an anomaly where a party could endlessly seek review, undermining the finality of judgments and the efficiency of the judicial system. The petitioner's action of filing a second certiorari petition after the first was dismissed, especially when the first court had jurisdiction to hear the initial petition, was deemed incongruous.
Main Doctrine
The writ of certiorari under Rule 65 of the Rules of Court is a special civil action that lies only on grounds of lack or excess of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction. It cannot be used as a substitute for a lost appeal or to review decisions that are already final and executory, especially when the same issues have been previously passed upon by a competent court, invoking the principle of res judicata.