G.R. No. 149739 ; July 14, 2006
STATE INVESTMENT HOUSE, INC., petitioner, vs. THE HONORABLE COURT OF APPEALS and ACTIVE WOOD PRODUCTS CO., INC., respondents.

FACTS

The protracted litigation originated from a 1982 complaint for injunction filed by Active Wood Products Co., Inc. (Active Wood) to prevent State Investment House, Inc. (State Investment) from extrajudicially foreclosing a real estate mortgage. The Regional Trial Court (RTC) issued orders nullifying a foreclosure sale and granting a preliminary injunction, which were ultimately upheld by the Supreme Court. After years of proceedings, including the filing of amended and supplemental complaints, Active Wood filed an omnibus motion in 1999, essentially seeking the dismissal of State Investment’s claims on grounds of prescription and payment. The RTC denied this motion and its subsequent motion for reconsideration.
Active Wood then filed a petition for certiorari with the Court of Appeals (CA), which issued a resolution requiring the parties to submit memoranda on the sole issue of whether State Investment’s action to foreclose the mortgage had already prescribed. State Investment opposed this, arguing the CA could not preemptively rule on prescription, which was a matter for the trial court’s determination after a full hearing. The CA denied State Investment’s motion for reconsideration, prompting the latter to elevate the case to the Supreme Court via the present petition for certiorari.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in issuing the assailed resolutions which confined the proceedings to the sole issue of prescription.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion by the Court of Appeals. The Court explained that the CA’s resolutions were merely interlocutory, procedural directives aimed at streamlining the case by focusing on a potentially decisive threshold issue—prescription. The CA had not yet rendered a final ruling on the merits of the prescription issue itself; it had only ordered the parties to argue it. A writ of certiorari under Rule 65 is a remedy designed to correct jurisdictional errors or acts performed without or in excess of jurisdiction, not to correct every debatable interlocutory order. Its function is to keep inferior courts within their jurisdiction, not to rectify alleged erroneous conclusions prematurely. The Court held that the petition was premature, as the CA had decided nothing final. Any objection to an eventual ruling on prescription should be raised only after such a ruling is promulgated. The Court noted that while the case had been delayed for years, the petitioner itself contributed to the delay by filing the instant petition instead of complying with the CA’s directive to submit the required memorandum.