[CIVPRO] Jurisdiction – 04
JRRB
A.L. ANG NETWORK, INC. VS. available where there is no appeal or any other plain,
speedy and adequate remedy in the ordinary course of
EMMA MONDEJAR law."
G.R. No. 200804, 22 January 2014| Perlas-Bernabe, J.:
Verily, a petition for certiorari, unlike an appeal, is an
FACTS
original action29 designed to correct only errors of
Petitioner filed a complaint for sum of money under
jurisdiction and not of judgment. Owing to its nature, it is
the Rule of Procedure for Small Claims Cases before
therefore incumbent upon petitioner to establish that
the MTCC,
jurisdictional errors tainted the MTCC Decision. The RTC,
in turn, could either grant or dismiss the petition based on
Petitioner seeks to collect the amount of P23,111.71 which
an evaluation of whether or not the MTCC gravely abused
represented her unpaid water bills for the period June 1,
its discretion by capriciously, whimsically, or arbitrarily
2002 to September 30, 2005.
disregarding evidence that is material to the controversy.
MTCC ruling: MTCC held that since petitioner was issued In view of the foregoing, the Court thus finds that
a Certificate of Public Convenience (CPC) by the National petitioner correctly availed of the remedy of certiorari to
Water Resources Board (NWRB) only on August 7, 2003, assail the propriety of the MTCC Decision in the subject
then, it can only charge respondent the agreed flat rate of
small claims case, contrary to the RTC’s ruling.
P75.00 per month prior thereto or the sum of P1,050.00
for the period June 1, 2002 to August 7, 2003. Thus, given
Likewise, the Court finds that petitioner filed the said
that respondent had made total payments equivalent to
petition before the proper forum (i.e., the RTC). To be
P1,685.99 for the same period, she should be considered sure, the Court, the Court of Appeals and the Regional
to have fully paid petitioner.
Trial Courts have concurrent jurisdiction to issue a writ of
certiorari. Such concurrence of jurisdiction, however,
Aggrieved, petitioner filed a petition for certiorari20 under does not give a party unbridled freedom to choose the
Rule 65 of the Rules of Court before the RTC, ascribing venue of his action lest he ran afoul of the doctrine of
grave abuse of discretion on the part of the MTCC in hierarchy of courts. Instead, a becoming regard for
finding that it (petitioner) failed to establish with certainty judicial hierarchy dictates that petitions for the issuance
respondent’s obligation, and in not ordering the latter to of writs of certiorari against first level courts should be
pay the full amount sought to be collected. filed with the Regional Trial Court, and those against the
latter, with the Court of Appeals, before resort may be had
RTC Ruling: petition for certiorari dismissed, finding that before the Court. This procedure is also in consonance
the said petition was only filed to circumvent the non- with Section 4, Rule 65 of the Rules of Court.
appealable nature of small claims cases as provided under
Section 2322 of the Rule of Procedure on Small Claims Hence, considering that small claims cases are exclusively
Cases. within the jurisdiction of the Metropolitan Trial Courts,
Municipal Trial Courts in Cities, Municipal Trial Courts, and
MR denied, hence, the instant petition. Municipal Circuit Trial Courts, certiorari petitions assailing
its dispositions should be filed before their corresponding
ISSUE(S) Regional Trial Courts. This petitioner complied with when
it instituted its petition for certiorari before the RTC which,
1. W/N the RTC erred in dismissing petitioner’s recourse as previously mentioned, has jurisdiction over the same.
under Rule 65 of the Rules of Court assailing the In fine, the RTC erred in dismissing the said petition on the
propriety of the MTCC Decision in the subject small ground that it was an improper remedy, and, as such, RTC
claims case. - YES Case No. 11-13833 must be reinstated and remanded
thereto for its proper disposition.
RULING
The petition is meritorious. Considering the final nature of DISPOSITIVE PORTION
a small claims case decision under the rule1, the remedy Petition is GRANTED.
of appeal is not allowed, and the prevailing party may,
thus, immediately move for its execution. Nevertheless,
the proscription on appeals in small claims cases, similar
to other proceedings where appeal is not an available
remedy, does not preclude the aggrieved party from filing
a petition for certiorari under Rule 65 of the Rules of
Court. In a long line of cases, the Court has consistently
ruled that "the extraordinary writ of certiorari is always
1 Section 23 of the Rule of Procedure for Small Claims Cases: 13-SCC). The decision shall immediately be entered by the Clerk of
Court in the court docket for civil cases and a copy thereof forthwith
Decision. — After the hearing, the court shall render its decision on
served on the parties.
the same day, based on the facts established by the evidence (Form
