G.R. No. 147525 ; February 26, 2007
Bonifacio Espinoza, Petitioner, vs. Provincial Adjudicator of the Provincial Agrarian Reform Adjudication Office of Pampanga and Maria Quibuloy, Respondents.

FACTS

Maria Quibuloy, as co-owner and administratrix, filed a complaint for ejectment against tenant Bonifacio Espinoza before the Provincial Agrarian Reform Adjudicator (PARAD) of Pampanga, alleging his failure to pay rent and till the land. Instead of filing an answer, Espinoza moved to dismiss the case for lack of jurisdiction. He argued that Quibuloy failed to present a Barangay Agrarian Reform Council (BARC) certification attesting to prior unsuccessful mediation, which he claimed was a jurisdictional requirement under the 1989 DARAB Rules. The PARAD did not immediately rule on this motion.
Espinoza and his counsel subsequently failed to appear at two scheduled hearings. Consequently, the PARAD allowed Quibuloy to present evidence ex-parte. Espinoza later filed an answer, offering only general denials. The PARAD ruled against Espinoza, ordering his ejectment. Espinoza did not appeal this decision within the reglementary period. Instead, months later, he filed a petition for certiorari with the Court of Appeals, which was dismissed. He then elevated the case to the Supreme Court.

ISSUE

The core issue is whether the Court of Appeals correctly dismissed Espinoza’s petition for certiorari, which challenged the PARAD’s proceedings and decision.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ dismissal. The Court held that a special civil action for certiorari is not a substitute for a lost appeal. Certiorari is only available to correct errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction, not errors of judgment. Espinoza lost his right to a regular appeal through his own negligence by allowing the 15-day appeal period to lapse. Having lost his appeal, he cannot resort to certiorari.
On the substantive arguments, the Court found no grave abuse of discretion by the PARAD. First, the BARC certification was not a jurisdictional requirement in this case. The 1989 DARAB Rules exempted parties residing in different, non-adjoining barangays from this prerequisite. Since Quibuloy and Espinoza resided in different barangays (San Nicolas 1st and San Agustin, Lubao, Pampanga), the exemption applied. Second, the PARAD’s failure to rule on the motion to dismiss before proceeding did not constitute grave abuse, as the motion was rendered moot by the finding that the certification was not required. Third, the PARAD’s decision based on ex-parte evidence was proper due to Espinoza’s unjustified absence from hearings. His belated answer contained only unsubstantiated denials, which did not constitute a valid defense.