The Supreme Court ruled that a direct appeal to the Supreme Court is erroneous if it involves factual matters, as the Court is not a trier of facts. The proper recourse for errors of judgment, as opposed to grave abuse of discretion, is an ordinary appeal, not a petition for certiorari. The case emphasizes adherence to the hierarchy of courts and the correct procedural remedies in challenging trial court decisions.

Cebu Woman’s Club: Navigating Retention Fees Amidst Multiple Claims

The case revolves around a construction project where Cebu Woman’s Club (petitioner) contracted CAMSAC International Inc. (CAMSAC) for the construction of the Cebu School of Midwifery Building. A key aspect of the contract was a 10% retention fee, to be released after project completion and CAMSAC’s assurance that all obligations, including salaries and materials, were settled. Subsequently, CAMSAC subcontracted part of the work to Phanuel Señoron. Disputes arose when Señoron filed a complaint against both Cebu Woman’s Club and CAMSAC, seeking to prevent the release of the retention fee to CAMSAC. This was compounded by demands from suppliers and CAMSAC itself for the release of the same retention fee, leading Cebu Woman’s Club to file an interpleader action to resolve the conflicting claims.

The trial court dismissed the interpleader action, citing the pendency of other cases involving the same retention fee, which it believed would lead to a multiplicity of suits. The court suggested that Cebu Woman’s Club should have filed an answer with a counterclaim or cross-claim in the existing case filed by Señoron. Aggrieved, Cebu Woman’s Club directly appealed to the Supreme Court, questioning the trial court’s jurisdiction and alleging grave abuse of discretion.

The Supreme Court, however, pointed out that a direct appeal to it is only permissible when it involves pure questions of law. In this case, the resolution required delving into factual matters, such as whether the pending cases indeed involved the same issues and arose from the same facts as the interpleader case. The Court emphasized that it is not a trier of facts and thus, the direct appeal was inappropriate. The Court cited Laza, et. al. v. Court Appeals et.al.[1997], 269 SCRA 654, underscoring the principle that factual disputes are to be resolved at the trial court level.

Moreover, the Supreme Court clarified the distinction between errors of jurisdiction and errors of judgment. While grave abuse of discretion, indicative of jurisdictional errors, can be corrected through a special civil action for certiorari, mere errors of judgment are correctible through an ordinary appeal. The Court noted that Cebu Woman’s Club’s imputation of grave abuse of discretion was a mischaracterization, as the trial court’s actions, even if erroneous, pertained to errors of judgment rather than jurisdictional defects. The court referenced Pure Blue Industries, Inc. v. NLRC et. al, 271 SCRA 259, highlighting that certiorari is not a remedy for errors that can be addressed through appeal.

The Court also addressed the procedural missteps in the petition. First, the trial judge should not have been impleaded as a party in a petition for review on certiorari, as stipulated in Regalado, Remedial Law Compendium, Book I, 5th Revised Edition, 1998, p. 352; Sec 4, Rule 45, 1997 Rules of Civil Procedure. Second, even if a certiorari action were appropriate, Cebu Woman’s Club should have observed the hierarchy of courts and initially sought recourse from the Court of Appeals, which has concurrent jurisdiction over such actions. The Court cited Morales v. Court of Appeals et. al., 283 SCRA 211 citing Article VIII, Section 5(1), 1987 Constitution, the Judiciary Act of 1945 and Section 21(1) of Batas Pambansa Blg. 129, emphasizing the importance of adhering to the established judicial hierarchy.

The decision underscores the importance of adhering to procedural rules and selecting the correct mode of appeal. It reiterates that the Supreme Court is not a trier of facts and that errors of judgment should be addressed through ordinary appeals, not through petitions for certiorari. Furthermore, the decision reinforces the principle of the hierarchy of courts, requiring parties to seek initial recourse from the lower courts before elevating matters to the Supreme Court. This principle ensures the efficient administration of justice and prevents the Supreme Court from being overburdened with cases that can be resolved at lower levels.

This case serves as a reminder to litigants to carefully assess the nature of their claims and choose the appropriate procedural remedy. It is crucial to distinguish between errors of judgment and errors of jurisdiction, as the former are correctible through ordinary appeal, while the latter may warrant a special civil action for certiorari. Additionally, parties must observe the hierarchy of courts and exhaust remedies at the lower levels before seeking recourse from the Supreme Court. Failure to adhere to these procedural requirements may result in the dismissal of the petition, as demonstrated in this case.

FAQs

What was the key issue in this case?	The key issue was whether the Cebu Woman’s Club correctly appealed the trial court’s dismissal of its interpleader complaint directly to the Supreme Court, alleging grave abuse of discretion. The Supreme Court assessed whether the issues raised were pure questions of law or involved factual determinations.
What is an interpleader action?	An interpleader action is a lawsuit initiated by a party (like Cebu Woman’s Club) who holds property or funds subject to conflicting claims by multiple parties. The stakeholder deposits the property with the court and allows the claimants to litigate their rights to the property among themselves.
Why did the trial court dismiss the interpleader complaint?	The trial court dismissed the interpleader complaint to prevent a multiplicity of suits, as there were already pending cases involving the same retention fee. The court suggested the Cebu Woman’s Club should have filed a counterclaim or cross-claim in the existing case.
What is the difference between an error of judgment and grave abuse of discretion?	An error of judgment is a mistake made by a court in its appreciation of facts or application of law, which is correctable by ordinary appeal. Grave abuse of discretion implies a capricious, arbitrary, or whimsical exercise of judgment, or the exercise of power in an arbitrary manner, correctable by certiorari.
What does it mean to say the Supreme Court is “not a trier of facts”?	This means the Supreme Court generally does not evaluate evidence or determine factual issues in the first instance. Its primary role is to review questions of law decided by lower courts, not to re-examine factual findings.
What is the hierarchy of courts, and why is it important?	The hierarchy of courts refers to the structured order of judicial bodies, from the lowest to the highest (Municipal Trial Courts, Regional Trial Courts, Court of Appeals, Supreme Court). It is important to follow this hierarchy to ensure that cases are heard and reviewed by the appropriate court levels, allowing for a systematic and orderly administration of justice.
What are the appropriate remedies when a trial court makes an error?	If the error is one of judgment, the appropriate remedy is an ordinary appeal to a higher court (e.g., Court of Appeals). If the error involves grave abuse of discretion or lack of jurisdiction, the proper remedy is a special civil action for certiorari.
Why was it incorrect for Cebu Woman’s Club to directly appeal to the Supreme Court?	It was incorrect because the appeal involved factual matters that needed to be resolved, and the Supreme Court is not a trier of facts. Additionally, Cebu Woman’s Club failed to observe the hierarchy of courts by not first seeking recourse from the Court of Appeals.

In summary, the Supreme Court denied the petition, emphasizing the importance of adhering to procedural rules, distinguishing between errors of judgment and jurisdiction, and observing the hierarchy of courts. Litigants must carefully assess the nature of their claims and choose the appropriate procedural remedy to ensure their cases are properly reviewed.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Cebu Woman’s Club vs. De la Victoria, G.R. No. 120060, March 09, 2000