In Teresita Pacaña Conejos v. Court of Appeals and Eutiquio Plania, the Supreme Court emphasized the importance of adhering to proper procedure when appealing decisions from the Court of Appeals. The Court ruled that filing a petition for certiorari after the reglementary period for filing a petition for review on certiorari had lapsed is a wrong remedy and cannot substitute for a lost appeal. This decision underscores the principle that certiorari is available only when there is no other plain, speedy, and adequate remedy, and it cannot be used to circumvent the prescribed appeal process. Understanding these procedural requirements is crucial for ensuring that legal rights are properly asserted and protected.

Missed Deadlines and Lost Appeals: A Case of Improper Remedy

The case originated from a dispute between Teresita Pacaña Conejos and Eutiquio Plania regarding a 134-square-meter residential lot in Cebu City. Plania claimed that they had an agreement to equally share the cost of the lot and divide it between themselves upon full payment. After Plania paid his share, Conejos allegedly refused to divide the lot as agreed. This led Plania to file a complaint for specific performance/rescission with damages.

The Municipal Trial Court in Cities (MTCC) initially dismissed Plania’s complaint, citing insufficient evidence. However, the Regional Trial Court (RTC) reversed the MTCC’s decision, ruling in favor of Plania. Conejos then appealed to the Court of Appeals (CA), which affirmed the RTC’s decision, finding no evidence of mutual abandonment of the agreement. Dissatisfied, Conejos filed a Petition for Certiorari with the Supreme Court, arguing that the Court of Appeals had gravely abused its discretion.

The Supreme Court, however, dismissed Conejos’s petition on procedural grounds. The Court emphasized that Conejos had chosen the wrong mode of appeal. After the Court of Appeals denied her motion for reconsideration, Conejos should have filed a petition for review on certiorari within fifteen days, as provided by the Rules of Court. Instead, she filed a petition for certiorari more than a month after the deadline. The Supreme Court cited the case of Republic v. Court of Appeals, stating that certiorari is not a substitute for a lost appeal:

Certiorari lies only where there is no appeal nor any plain, speedy, and adequate remedy in the ordinary course of law. There is no reason why the question being raised by petitioner, i.e., whether the appellate court committed a grave abuse of discretion in dismissing petitions, could not have been raised on appeal.

The Court acknowledged that there were instances where a petition for certiorari was treated as one filed under Rule 45. However, the circumstances in this case did not warrant such a deviation. The Court noted that Conejos’s petition was filed way beyond the reglementary period without any justifiable reason or reasonable explanation. Furthermore, the Court found no merit in Conejos’s arguments, which were essentially a rehash of the issues already resolved by the lower courts. The Court emphasized that it is not a trier of facts and that both the trial and appellate courts did not abuse their discretion in their factual findings.

This decision highlights the strict adherence to procedural rules in the Philippine legal system. The failure to follow the correct procedure and meet deadlines can result in the dismissal of a case, regardless of its merits. It also underscores the limited scope of certiorari, which is generally available only when there is no other adequate remedy. Parties seeking to appeal decisions must ensure that they file the appropriate petition within the prescribed period to avoid losing their right to appeal.

The Supreme Court’s ruling serves as a cautionary tale for litigants and legal practitioners alike. It reinforces the principle that procedural rules are not mere technicalities but are essential for the orderly and efficient administration of justice. The Court’s decision also clarifies the distinction between a petition for review on certiorari and a petition for certiorari, emphasizing that the latter cannot be used as a substitute for the former when the period for filing the former has already lapsed.

FAQs

What was the key issue in this case?	The key issue was whether the petitioner properly availed of the remedy of certiorari after failing to file a timely petition for review on certiorari.
What is a petition for certiorari?	A petition for certiorari is a special civil action filed to correct errors of jurisdiction committed by a lower court or tribunal, or when there is grave abuse of discretion amounting to lack or excess of jurisdiction.
What is a petition for review on certiorari?	A petition for review on certiorari is the mode of appeal to the Supreme Court from decisions of the Court of Appeals, involving questions of law.
Why was the petition for certiorari dismissed in this case?	The petition was dismissed because it was filed after the reglementary period for filing a petition for review on certiorari had lapsed, and certiorari cannot be used as a substitute for a lost appeal.
What is the reglementary period for filing a petition for review on certiorari?	The reglementary period for filing a petition for review on certiorari is fifteen (15) days from receipt of the resolution denying the motion for reconsideration.
What was the original dispute about?	The original dispute was about an agreement between two parties to equally share the cost of a residential lot and divide it between themselves upon full payment, which one party allegedly failed to honor.
What did the lower courts rule?	The Municipal Trial Court initially dismissed the complaint, but the Regional Trial Court reversed the decision, ruling in favor of the plaintiff. The Court of Appeals affirmed the Regional Trial Court’s decision.
What is the significance of this Supreme Court decision?	The decision emphasizes the importance of adhering to proper procedure and meeting deadlines when appealing decisions, and clarifies the distinction between certiorari and a petition for review on certiorari.

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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: TERESITA PACAÑA CONEJOS, VS. COURT OF APPEALS AND EUTIQUIO PLANIA, G.R. No. 149473, August 09, 2002