SAINT MARY CRUSADE V HON.
TEODORO RIEL
FACTS: Petitioner Saint Mary Crusade claimed in its petition for reconstitution that the
original copy of OCT 1609 had been burnt and lost in the fire that gutted the Quezon
City Register of Deeds in the late ’80s but the respondent Acting Presiding Judge of
Branch 85 of the Regional Trial Court (RTC) in Quezon City dismissed the petition
considering the following: that petitioner did not present its purported Torrens title to be
reconstituted; that the petitioner’s claim was doubtful given the magnitude of 4,304,623
square meters as the land area involved;12 and that the UP’s ownership of the portion
of land covered by petitioner’s claim had long been settled by the Court in a long line of
cases. Saint Mary moved for reconsideration of the dismissal but it was dismissed for
lack of any cogent or justifiable ground to reconsider. As a result, they sought a direct
resort to the Supreme Court by petition for certiorari and mandamus alleging that the
respondent Judge committed grave abuse of discretion and unlawful neglect of
performance of an act specifically enjoined upon him.
ISSUE: Whether or not the case be dismissed for lack of jurisdiction.
RULING: Yes. The petition for certiorari and mandamus, being devoid of procedural and
substantive merit, is dismissed by the Supreme Court. The filing of the instant special
civil action directly in this Court is in disregard of the doctrine of hierarchy of courts.
Although the Court has concurrent jurisdiction with the Court of Appeals in issuing the
writ of certiorari, direct resort is allowed only when there are special, extraordinary or
compelling reasons that justify the same. The Court enforces the observance of the
hierarchy of courts in order to free itself from unnecessary, frivolous, and impertinent
cases and thus afford time for it to deal with the more fundamental and more essential
tasks that the Constitution has assigned to it. There being no special, important, or
compelling reason, the petitioner thereby violated the observance of the hierarchy of
courts, warranting the dismissal of the petition for certiorari. The correct recourse for the
petitioner was to appeal to the Court of Appeals by notice of appeal within 15 days from
notice of the denial of its motion for reconsideration.