G.R. Nos. L-19930-35, November 30, 1962
Estanislao Abaga, Alejandro Costa, et al., petitioners, vs. Hon. Pastor L. de Guzman, Judge of the Court of Agrarian Relations, First Regional District, Lingayen, Pangasinan, Rene Lichauco, Amanda Vda. de la Cruz, et al., respondents.

FACTS

Respondent landowners filed six ejectment and collection cases against their tenants, including petitioners, in the Court of Agrarian Relations (CAR). The Land Tenure Administration intervened, citing a pending expropriation case over the hacienda and invoking Section 20 of Republic Act No. 1400 , which prohibits ejectment proceedings while expropriation is pending. The expropriation case was later partially settled, with the government purchasing only certain portions of the land. On March 29, 1962, respondent Judge de Guzman rendered a decision ordering the ejectment of tenants who failed to pay rentals without justifiable cause, except those on land purchased by the government. Petitioners received the decision on April 12, filed but withdrew a notice of appeal, and instead filed a motion for reconsideration, which was denied on June 25, 1962.
Petitioners received the denial order on July 5, 1962, two days before their appeal period expired. Instead of perfecting an appeal, they filed this special civil action for certiorari with the Supreme Court. Their petition merely chronologically listed the pleadings and incidents from the lower court, annexing the voluminous records, including a 304-page decision. It contained no specific allegations that the respondent Judge acted without jurisdiction or with grave abuse of discretion.

ISSUE

Whether the special civil action for certiorari filed by the petitioners is proper and sufficient in form and substance.

RULING

No, the petition must be dismissed. The Supreme Court clarified the proper procedural avenues. A review of a Court of Agrarian Relations decision is governed by Rule 44, which provides for an appeal by certiorari requiring a petition filed with the Supreme Court within ten days from notice, containing a summary of issues and distinctly set forth questions of law. Alternatively, an original action for certiorari under Rule 67 requires allegations of lack or excess of jurisdiction or grave abuse of discretion. The petitioners’ filing failed under both rules.
Their petition was procedurally defective. Treated as an original certiorari action (Rule 67), it was insufficient for its bare, summary allegations that failed to specify any jurisdictional error or grave abuse by the trial judge. Treated as an appeal by certiorari (Rule 44), it was likewise improper as it was not filed as such and, critically, petitioners failed to file the required brief or memorandum within the prescribed period after respondents’ answers. The Court emphasized that the formulation of specific issues is the petitioner’s burden. It cannot sift through voluminous, unindexed records to find errors petitioners themselves failed to raise. For these procedural lapses, the petition was dismissed.