G.R. No. 186199. September 07, 2016
EDGARDO A. QUILO AND ADNALOY VILLAHERMOSA, PETITIONERS, VS. TEODULA BAJAO, RESPONDENT.
FACTS
This case originated from an ejectment complaint filed by respondent Teodula Bajao against several defendants concerning a property on Granate Street, Manila. The Metropolitan Trial Court (MeTC) ruled in favor of Bajao in 1998. This decision was affirmed by the Regional Trial Court (RTC) and eventually became final and executory in 2000 after the defendants’ appeals were denied by the Court of Appeals and the Supreme Court. A writ of execution was subsequently issued by the MeTC in 2007. Petitioners Edgardo Quilo and Adnaloy Villahermosa, who were occupying the property but were not original parties to the ejectment case, received a notice to vacate. They filed a Motion to Quash the Writ of Execution, arguing it was issued beyond the five-year period for execution under Rule 39 and that it erroneously targeted them and a different property address (2518 instead of 2519 Granate Street). The MeTC denied their motion, finding the properties were identical and that the writ bound all occupants claiming under the defeated defendants.
Petitioners then filed a petition for certiorari under Rule 65 before the RTC, challenging the MeTC’s orders. The RTC denied this petition due to procedural defects: petitioners failed to attach a certified true copy of the original 1998 MeTC decision, violating Section 1, Rule 65. Their subsequent Motion for Reconsideration, which attached certified copies of the later MeTC orders but not the 1998 decision, was also denied for the same omission and for allegedly violating the three-day notice rule under Rule 15. Petitioners elevated the matter to the Supreme Court via a Petition for Review on Certiorari under Rule 45.
ISSUE
Whether the Regional Trial Court committed reversible error in dismissing the petition for certiorari based on procedural grounds, specifically the failure to attach a certified true copy of the original MeTC decision.
RULING
The Supreme Court denied the petition and affirmed the RTC’s dismissal. The Court emphasized that a petition for certiorari under Rule 65 is an original action, not an appeal. As such, strict compliance with its procedural requirements is mandatory. Section 1, Rule 65 explicitly requires that the petition be accompanied by a certified true copy of the judgment, order, or resolution subject thereof. The purpose is to enable the reviewing court to verify the factual and legal bases of the alleged grave abuse of discretion. The original 1998 MeTC decision was the foundational ruling that culminated in the challenged 2007 writ of execution. Its omission was fatal, as the later orders denying the motion to quash were merely interlocutory and could not be properly evaluated in isolation from the final judgment they sought to enforce.
The Court rejected petitioners’ argument that the certified copies of the 2008 MeTC orders were sufficient. The requirement to attach the certified true copy of the assailed judgment is jurisdictional. Failure to comply warrants the petition’s dismissal. The RTC correctly applied this rule. The Court also found no merit in the claim that the five-year period for execution had lapsed, noting that the motion for execution was filed in 2000, well within the period, and that subsequent delays did not invalidate the writ. The identity of the property was settled by the MeTC’s factual finding, supported by evidence, that the address discrepancy was merely a later alteration. Thus, the RTC committed no reversible error in its procedural dismissal.
