Biñan Transportation Co. v. Ibañez
REITERATIONFacts
The Antecedents: The underlying dispute originated from a civil case filed by respondents against petitioner, Biñan Transportation Company, Inc., for damages amounting to P4,900. The petitioner filed its answer, and a hearing was scheduled for January 5, 1942. However, due to the Japanese invasion, the petitioner and its counsel were unable to attend. The hearing proceeded on February 2, 1943, without notice to the petitioner, and a decision was rendered on March 22, 1943, also without notice to the petitioner. Procedural History: Following the liberation of the Philippines, the record of the case was lost. On November 26, 1946, a petition for the reconstitution of the case record was filed and granted on December 20, 1946. The petitioner, upon learning of the March 22, 1943 decision after its reconstitution, filed motions for a new trial and for relief from judgment, alleging lack of notice. These motions were denied by the respondent judge as untimely. Subsequently, the respondent judge issued an order for execution on June 28, 1947, which led to the seizure of the petitioner's property. The Petition: The petitioner filed a petition for certiorari with the Supreme Court, arguing that the respondent judge acted without jurisdiction or with grave abuse of discretion in issuing the order of execution. The petitioner contends that the original judgment of March 22, 1943, is null and void due to lack of notice of the hearing and the rendition of the decision. The petitioner also argues that the reconstitution of the record and the subsequent orders were invalid as they were based on a void judgment and that the denial of its motions for new trial and relief from judgment was erroneous.
Issue(s)
Whether the respondent judge acted without jurisdiction or with grave abuse of discretion in issuing the order of execution. Whether the judgment dated March 22, 1943, is null and void for lack of notice to the petitioner. Whether the denial of the petitioner's motions for new trial and relief was proper.
Ruling
The petition for certiorari is denied. The Supreme Court held that the respondent judge did not act without jurisdiction or with grave abuse of discretion. The Court found that the petitioner's proper remedy was an appeal, not certiorari, as the alleged errors did not amount to an excess of jurisdiction. The Court also upheld the presumption of regularity in official acts, including the presumption that the petitioner was duly notified.
Ratio Decidendi
On the issue of whether the respondent judge acted without jurisdiction or with grave abuse of discretion in issuing the order of execution: The Supreme Court reiterated that a petition for certiorari under Rule 65 is an extraordinary remedy and is only available when a tribunal, board, or officer exercising judicial, quasi-judicial, or ministerial functions has acted without or in excess of its jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction. In this case, the respondent judge had jurisdiction over the case and the parties. The alleged error in denying the motions for new trial and relief, even if erroneous, did not constitute an act without or in excess of jurisdiction, nor did it amount to grave abuse of discretion. Therefore, certiorari was not the proper remedy. The Court emphasized that if the judge erred in denying the motion for relief, the petitioner's recourse should have been an appeal. On the issue of whether the judgment dated March 22, 1943, is null and void for lack of notice to the petitioner: The Court invoked the presumption juris tantum that official duty has been regularly performed and that the law has been obeyed, as provided in Section 69, subsections (m) and (ee) of Rule 123 of the Rules of Court. This presumption implies that the petitioner was duly notified of the trial and the rendition of the decision. This presumption can only be rebutted by evidence to the contrary presented at a hearing, which may be granted upon a motion for relief filed under Rule 38. However, the respondent judge denied the motion for relief because it was filed beyond the period fixed by Rule 38. The Court noted that the order of execution contained an uncontradicted recital of dates indicating that petitioner's counsel was notified or became aware of the decision and filed their motion for new trial and relief. The Court also pointed out that the reconstitution of the record on December 20, 1946, was done with notice to the defendant (petitioner), and the counsel for the petitioner was present during the reconstitution proceedings and offered no objection to the reconstitution of the decision, implying constructive notice. On the issue of whether the denial of the petitioner's motions for new trial and relief was proper: The respondent judge denied the motions for new trial and relief on the ground that they were filed after the periods fixed by law had elapsed. The Court found this denial to be within the respondent judge's discretion, especially in light of the presumption of regularity and the petitioner's failure to file the motions within the prescribed statutory periods. The Court also noted that the petitioner's counsel was present during the reconstitution proceedings and did not object to the reconstitution of the decision, which was declared reconstituted on December 20, 1946. The subsequent motions for new trial and relief were filed much later, leading to their denial as time-barred. The Court concluded that the respondent judge did not commit a grave abuse of discretion in denying these motions, as the petitioner failed to comply with the procedural requirements and timelines set forth in the Rules of Court.
Main Doctrine
A petition for certiorari under Rule 65 is not a substitute for an appeal. It is only available when the respondent court or tribunal has acted without or in excess of its jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction. If the court has jurisdiction but allegedly erred in denying a motion for new trial or relief, the proper remedy is an appeal, not certiorari, as such an error does not amount to excess of jurisdiction.