The Supreme Court in Guzman v. Guzman affirmed the dismissal of a petition for certiorari, reiterating that it is not a substitute for a lost appeal. The petitioner incorrectly used a Rule 65 petition to question the Regional Trial Court’s (RTC) decision, which should have been challenged through a Rule 42 petition for review. This ruling underscores the importance of adhering to procedural rules, especially regarding the timely filing of appeals and the prohibition against second motions for reconsideration. Failure to comply results in the finality of the lower court’s decision, precluding further judicial review.

Navigating Procedural Pitfalls: When Certiorari Cannot Salvage a Lost Appeal

This case arose from a dispute between Isabel N. Guzman and her children, Aniano N. Guzman and Primitiva G. Montealto, over a parcel of land in Tuguegarao City. Isabel filed an ejectment case against Aniano and Primitiva, alleging that they occupied the land by tolerance and refused to vacate despite demands. The Municipal Trial Court (MTC) ruled in Isabel’s favor, but the RTC reversed this decision, taking into account a prior transfer of rights in favor of the children. Dissatisfied, Isabel filed multiple motions for reconsideration and eventually a petition for certiorari with the Court of Appeals (CA), which dismissed the petition. The Supreme Court was then asked to determine if the CA erred in dismissing Isabel’s petition.

The Supreme Court emphasized that Isabel availed herself of the wrong remedy. When the RTC decides a case on appeal from the MTC, the proper recourse is a petition for review under Rule 42 of the Rules of Court, not a petition for certiorari under Rule 65. The Court noted the importance of following proper procedure. Furthermore, Isabel’s filing of a second motion for reconsideration was a prohibited pleading, which caused her to lose her right to appeal. The Court cited established jurisprudence on the immutability of final judgments, noting that:

Once a decision becomes final and executory, it is “immutable and unalterable, and can no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest court of the land.”

The Court clarified that certiorari is only appropriate when appeal is not available, and it cannot be used as a substitute for a lost appeal due to one’s own negligence or error in choosing the correct remedy. This principle is crucial in maintaining the orderly administration of justice and preventing abuse of judicial processes. In this context, the Supreme Court underscored the distinct and non-interchangeable nature of these legal remedies, elaborating that:

Certiorari, by its very nature, is proper only when appeal is not available to the aggrieved party; the remedies of appeal and certiorari are mutually exclusive, not alternative or successive. It cannot substitute for a lost appeal, especially if one’s own negligence or error in one’s choice of remedy occasioned such loss or lapse.

Even if the petition for certiorari had been properly filed, the Supreme Court found no grave abuse of discretion on the part of the RTC. Grave abuse of discretion implies such capricious and whimsical exercise of judgment as is equivalent to lack of jurisdiction. The Court clarified that the RTC’s actions, even if erroneous, amounted to errors of judgment, not errors of jurisdiction, and were therefore not correctable via certiorari. The Court elucidated the limited scope of certiorari, reiterating that:

As a legal recourse, certiorari is a limited form of review. It is restricted to resolving errors of jurisdiction and grave abuse of discretion, not errors of judgment. Indeed, as long as the lower courts act within their jurisdiction, alleged errors committed in the exercise of their discretion will amount to mere errors of judgment correctable by an appeal or a petition for review.

The Court also addressed the RTC’s consideration of the petitioner’s transfer of rights, even though it was not specifically raised as an issue on appeal. The Court explained that the RTC was within its authority to consider the entire record of the MTC proceedings in arriving at a just decision. Furthermore, appellate courts have the authority to review matters not assigned as errors on appeal if their consideration is necessary for a just resolution. The Supreme Court supported its reasoning by stating that:

…an appellate court is clothed with ample authority to review matters, even if they are not assigned as errors on appeal, if it finds that their consideration is necessary in arriving at a just decision of the case, or is closely related to an error properly assigned, or upon which the determination of the question raised by error properly assigned is dependent.

The Supreme Court also supported the RTC’s strict enforcement of the notice of hearing requirement. The Supreme Court supported its reasoning by stating that:

The requirement of notice of hearing is an integral component of procedural due process that seeks to avoid “surprises that may be sprung upon the adverse party, who must be given time to study and meet the arguments in the motion before a resolution by the court.”

The case serves as a reminder that ejectment cases are summary proceedings focused on possession, not title. The Supreme Court noted that:

Ejectment cases are summary proceedings intended to provide an expeditious means of protecting actual possession or right of possession of property. Title is not involved, hence, it is a special civil action with a special procedure. The only issue to be resolved in ejectment cases is the question of entitlement to the physical or material possession of the premises or possession de facto. Thus, any ruling on the question of ownership is only provisional, made solely for the purpose of determining who is entitled to possession de facto.

Therefore, any determination regarding the validity of the petitioner’s transfer of rights is provisional and should be resolved in a separate, appropriate proceeding.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals erred in dismissing the petitioner’s petition for certiorari, which was used to challenge a Regional Trial Court decision in an ejectment case. The Supreme Court found that certiorari was the wrong remedy and that the petitioner had lost their right to appeal by filing a prohibited pleading.
What is the correct procedure to appeal an RTC decision in an ejectment case?	The correct procedure is to file a petition for review under Rule 42 of the Rules of Court. This is applicable when the RTC is exercising its appellate jurisdiction, meaning it is reviewing a decision from a lower court.
Why was the petitioner’s second motion for reconsideration considered a fatal error?	Under Section 5, Rule 37 of the Rules of Court, a second motion for reconsideration is a prohibited pleading. Filing it does not stop the clock on the period to appeal, and it causes the decision to become final and executory.
What is the difference between certiorari and appeal?	Certiorari is a remedy used to correct errors of jurisdiction or grave abuse of discretion when there is no appeal available. Appeal, on the other hand, is used to correct errors of judgment. They are mutually exclusive remedies.
What does ‘grave abuse of discretion’ mean in a legal context?	‘Grave abuse of discretion’ implies an arbitrary or despotic exercise of power, equivalent to a lack of jurisdiction. It means the court exercised its judgment in a capricious, whimsical, or arbitrary manner.
Can an appellate court consider issues not raised on appeal?	Yes, an appellate court can review matters not assigned as errors if their consideration is necessary for a just decision, or if they are closely related to a properly assigned error. This is to ensure a fair and complete resolution of the case.
What is the significance of the notice of hearing requirement?	The notice of hearing is a crucial part of procedural due process, ensuring that the opposing party has time to prepare and respond to the arguments presented in a motion. A motion without proper notice is considered a mere scrap of paper.
Are rulings on ownership in ejectment cases final and binding?	No, rulings on ownership in ejectment cases are provisional and only for determining who has the right to possess the property. A separate action is required to definitively resolve issues of ownership.
What is the main purpose of ejectment proceedings?	Ejectment proceedings are summary in nature, designed to quickly resolve issues of physical possession of a property. They are not intended to be a forum for deciding complex questions of ownership or title.

This case underscores the critical importance of understanding and adhering to the Rules of Court, particularly regarding the proper remedies and timelines for appealing decisions. Failure to do so can result in the loss of the right to appeal and the finality of adverse judgments.

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: ISABEL N. GUZMAN v. ANIANO N. GUZMAN, G.R. No. 172588, March 18, 2013