In ejectment cases governed by summary procedure, the Supreme Court has definitively ruled that petitions for certiorari against interlocutory orders are prohibited. This means that any challenges to preliminary decisions made by the lower court during the ejectment process must wait until the final judgment is appealed. This mandate ensures that these cases, designed for quick resolution, are not bogged down by procedural delays, thus protecting the rights of property owners to regain possession swiftly and efficiently.

Victorias Milling vs. IPI: Upholding the Swift Resolution of Ejectment Disputes

The case of Victorias Milling Co., Inc. v. Court of Appeals and International Pharmaceuticals, Inc. (G.R. No. 168062, June 29, 2010) revolves around the crucial issue of whether a petition for certiorari can be used to challenge an interlocutory order in an ejectment case. Victorias Milling Co. (VMC) filed an ejectment case against International Pharmaceuticals, Inc. (IPI). IPI, in turn, questioned the jurisdiction of the Municipal Circuit Trial Court (MCTC) over its person due to improper service of summons, and then filed a petition for certiorari with the Court of Appeals (CA) seeking to halt the proceedings. The CA granted a preliminary injunction, stopping the MCTC from proceeding with the ejectment case. VMC then elevated the matter to the Supreme Court, arguing that the CA’s action violated the rule against challenging interlocutory orders in ejectment cases via certiorari.

At the heart of this case lies the interpretation and application of the **Rule on Summary Procedure**, particularly concerning prohibited pleadings and motions in ejectment cases. The Rules of Court explicitly state:

Sec. 13. Prohibited pleadings and motions.-The following petitions, motions, or pleadings shall not be allowed:

7. Petition for certiorari, mandamus, or prohibition against any interlocutory order issued by the court;

This rule is designed to prevent delays in the resolution of ejectment cases, which are intended to be processed swiftly. The Supreme Court emphasized this point, stating that “the purpose of the Rule on Summary Procedure is to achieve an expeditious and inexpensive determination of cases without regard to technical rules.” The key question before the Supreme Court was whether the CA erred in entertaining IPI’s petition for certiorari, which sought to question an interlocutory order of the MCTC.

The Supreme Court found that the CA had indeed erred. The Court underscored that the prohibition against petitions for certiorari is clear and categorical, and that there was no substantive injustice that would warrant a deviation from this rule. While IPI argued that the improper service of summons raised jurisdictional concerns, the Court noted that IPI had already filed an answer and participated in the proceedings before the MCTC. This participation, according to the Court, mitigated any potential prejudice arising from the alleged improper service.

Furthermore, the Court clarified that the **Rule on Summary Procedure** only permits a motion to dismiss on the ground of lack of jurisdiction over the *subject matter*, not over the *person*. It invoked the principle of *expressio unius est exclusio alterius*, meaning the express mention of one thing implies the exclusion of all others. This principle reinforced the Court’s view that challenges to personal jurisdiction, without a showing of substantive injustice, should not be used to obstruct ejectment proceedings.

The Supreme Court distinguished the present case from Go v. Court of Appeals, a case cited by IPI to justify the CA’s actions. In *Go*, the trial court had ordered an “indefinite suspension” of the ejectment case, creating a “procedural void.” In contrast, the VMC case did not involve any such suspension or void. The Court emphasized that the facts were the “exact opposite,” and that the MCTC was proceeding with the case in a summary and expeditious manner.

The Supreme Court’s decision in *Victorias Milling* reinforces the importance of adhering to procedural rules, particularly in cases governed by summary procedure. The Court recognized that allowing petitions for certiorari against interlocutory orders would undermine the very purpose of the Rule on Summary Procedure, which is to provide a swift and inexpensive resolution of ejectment cases. By prohibiting such petitions, the Court sought to prevent unnecessary delays and ensure that property rights are protected without undue hindrance.

This ruling has significant implications for both landlords and tenants. For landlords, it provides assurance that they can pursue ejectment cases without being subjected to dilatory tactics by tenants seeking to prolong their stay on the property. For tenants, it underscores the importance of raising all defenses and objections during the initial proceedings before the MCTC, as they will not be able to challenge interlocutory orders through a separate petition for certiorari.

Moreover, the decision highlights the principle of judicial hierarchy. The Supreme Court noted that IPI filed its petition for certiorari directly with the CA, rather than the Regional Trial Court (RTC). While the Court did not explicitly address this issue, it implied that the principle of hierarchy of courts should be respected, and that parties should generally exhaust remedies in the lower courts before seeking relief from higher courts. The Supreme Court ultimately granted VMC’s petition, nullifying the CA’s resolution and ordering the dismissal of IPI’s petition for certiorari. This decision reaffirms the prohibition against challenging interlocutory orders in ejectment cases via certiorari, and it underscores the importance of adhering to the Rule on Summary Procedure to ensure the swift and efficient resolution of these disputes.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals (CA) erred in issuing a writ of preliminary injunction to stop an ejectment case based on a petition for certiorari challenging an interlocutory order.
What is an interlocutory order?	An interlocutory order is a temporary decision made by a court during a case that does not resolve the entire case but deals with a specific matter.
What is the Rule on Summary Procedure?	The Rule on Summary Procedure aims to expedite the resolution of certain cases, including ejectment cases, by simplifying procedures and limiting delays.
Why are petitions for certiorari generally prohibited in ejectment cases under summary procedure?	These petitions are prohibited to prevent unnecessary delays in resolving ejectment cases, which are meant to be decided quickly.
What did the Supreme Court decide in this case?	The Supreme Court ruled that the CA erred in entertaining the petition for certiorari and issuing the injunction, reinforcing the prohibition against such petitions in ejectment cases.
What is the meaning of “expressio unius est exclusio alterius”?	It’s a principle of statutory construction meaning that the express mention of one thing excludes all others, used here to highlight that only lack of subject matter jurisdiction allows a motion to dismiss.
How does this ruling affect landlords?	It assures landlords that they can pursue ejectment cases without facing dilatory tactics from tenants aimed at prolonging their stay.
How does this ruling affect tenants?	It highlights the importance of raising all defenses during the initial proceedings, as challenging interlocutory orders through certiorari is not allowed.
What was the Court’s basis for distinguishing this case from Go v. Court of Appeals?	Unlike in Go, there was no “indefinite suspension” or “procedural void” in this case, and the MCTC was proceeding with the case in a summary manner.

The Supreme Court’s decision in *Victorias Milling* serves as a clear reminder of the importance of adhering to procedural rules and respecting the principles of summary procedure in ejectment cases. By preventing parties from using petitions for certiorari to challenge interlocutory orders, the Court has helped to ensure that these cases are resolved swiftly and efficiently, thereby protecting the rights of all parties involved.

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: Victorias Milling Co., Inc. v. Court of Appeals and International Pharmaceuticals, Inc., G.R. No. 168062, June 29, 2010