G.R. No. 138203; July 3, 2002
LILIA J. VICOY, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.

FACTS

Petitioner Lilia Vicoy was convicted by the Municipal Trial Court in Cities (MTCC) of Tagbilaran on August 24, 1995, for violating a city ordinance and for resistance and serious disobedience to a person in authority. On the same day, she filed an application for probation. However, on September 18, 1995, she moved to withdraw this application and simultaneously filed a notice of appeal. The MTCC granted the withdrawal but denied the notice of appeal for being filed out of time, a decision upheld upon motion for reconsideration.
Vicoy subsequently filed a special civil action for certiorari with the Regional Trial Court (RTC) of Bohol, alleging grave abuse of discretion by the MTCC in denying her appeal. The RTC, after the parties submitted memoranda, issued an Order on August 2, 1996, directing Vicoy’s counsel to furnish the City Prosecutor’s Office with copies of her memorandum and the assailed judgment, as the People of the Philippines was a named respondent. Vicoy failed to comply with this directive.

ISSUE

Whether the Regional Trial Court validly dismissed the petition for certiorari due to petitioner’s failure to comply with its August 2, 1996 Order.

RULING

Yes, the dismissal was valid. The Supreme Court affirmed the RTC’s Orders. The legal logic rests on two independent grounds. First, under Section 3, Rule 17 of the Rules of Court, a court may dismiss an action if the plaintiff fails to comply with the Rules or any lawful order. The RTC’s August 2, 1996 Order was a direct and lawful instruction to petitioner’s counsel. The failure to comply, without justifiable cause, warranted the dismissal of the certiorari petition. The Court emphasized that every court possesses the inherent power to enforce obedience to its orders to ensure the orderly administration of justice. Petitioner’s excuse that the City Prosecutor had not yet entered an appearance was deemed insufficient to justify non-compliance.
Second, and more fundamentally, the Supreme Court held that even if the RTC had not dismissed the case, the certiorari petition would still fail on substantive grounds. By filing an application for probation immediately after her conviction, petitioner was deemed to have waived her right to appeal under Section 4 of the Probation Law (P.D. No. 968). This waiver is explicit and results in the judgment becoming final. Consequently, the MTCC’s subsequent denial of her belated notice of appeal was correct, and there was no grave abuse of discretion to warrant certiorari. Thus, the RTC’s dismissal, whether based on procedural non-compliance or the substantive meritlessness of the petition, was legally sound.