GR 132250; (March, 1999) (Digest)
G.R. No. 132250 March 11, 1999
ROSALIA P. SALVA, et al., petitioners, vs. COURT OF APPEALS and GOVERNOR JOSEPHINE R. SATO, respondents.
FACTS
The San Jose Airport in Occidental Mindoro was closed due to squatters. To reopen it, provincial officials, led by Governor Josephine Sato, initiated a relocation program. The Sangguniang Bayan selected a lot owned by the National Food Authority (NFA) as the relocation site. Petitioners, the Salva family, had long been occupying portions of this NFA land, as evidenced by tax declarations, affidavits, and improvements like houses and plantations. After the relocation, petitioners filed a forcible entry complaint against the relocated families and Governor Sato in the Municipal Trial Court (MTC). The MTC ruled for the Salvas, finding they were in prior physical possession and were unlawfully dispossessed. The Regional Trial Court (RTC) affirmed this after an ocular inspection. Governor Sato appealed to the Court of Appeals (CA).
ISSUE
Whether the Court of Appeals correctly granted Governor Sato’s Motion for Reconsideration and dismissed the petition for certiorari, thereby effectively overturning the final and executory judgments of the MTC and RTC in the forcible entry case.
RULING
The Supreme Court ruled in favor of the petitioners, the Salva family. The Court held that the CA committed grave abuse of discretion. The RTC decision in the forcible entry case had long become final and executory. Governor Sato’s initial appeal to the CA (CA-G.R. CV No. UDK-3880-A) was dismissed for adopting a wrong mode of appeal, and she allowed this dismissal to become final. She subsequently filed a petition for certiorari (CA-G.R. SP No. 40430) to assail the same RTC decision. This was impermissible. A special civil action for certiorari under Rule 65 cannot be used as a substitute for a lost appeal, especially when the loss was due to the party’s own negligence. The doctrine of finality of judgment, or immutability of judgments, applies. Once a judgment becomes final, it can no longer be modified. Allowing a certiorari petition under these circumstances would violate this fundamental rule and sanction endless litigation. The MTC and RTC correctly found for the Salvas in the forcible entry case, as the sole issue therein was prior physical possession, which they sufficiently proved. The Supreme Court reinstated the CA’s original decision which had dismissed Governor Sato’s certiorari petition.