GR 165258; (February, 2008) (Digest)
G.R. No. 165258 ; February 4, 2008
ROSITA L. FLAMINIANO a.k.a. ROSE FLAMINIANO, petitioner, vs. HON. ARSENIO P. ADRIANO, Pairing Judge (RTC, Branch 64, Tarlac City), S.Q. FILMS LABORATORIES, INC., ALBERTO Q. SANTOS, SUSAN MANSUETO and ANGELITA LIMSON, respondents.
FACTS
Petitioner Rosita Flaminiano, a movie producer, was charged with two counts of violation of B.P. 22 by private respondent S.Q. Films Laboratories, Inc. (SQ Lab). After a warrant for her arrest was issued, she was apprehended by NBI agents following a meeting with SQ Lab’s sales representative, Angelita Limson. Flaminiano subsequently filed a civil complaint for damages against the private respondents in the RTC of Tarlac City, alleging her arrest was executed in bad faith to harass her. The case was originally heard by Judge Martonino Marcos.
Judge Marcos was suspended before rendering a decision. Public respondent Judge Arsenio P. Adriano, as pairing judge, took over the case and dismissed the complaint. He also ordered Flaminiano to pay moral damages and attorney’s fees to the private respondents. Flaminiano’s motion for reconsideration was denied.
ISSUE
Whether public respondent Judge Arsenio P. Adriano committed grave abuse of discretion amounting to lack or excess of jurisdiction in deciding the civil case for damages.
RULING
The Supreme Court dismissed the petition. The Court found no grave abuse of discretion on the part of Judge Adriano. The petition was procedurally infirm for disregarding the doctrine of hierarchy of courts, as a petition for certiorari should have been filed with the Court of Appeals, not directly with the Supreme Court. More fundamentally, the proper remedy for the errors petitioner ascribed was an appeal, not certiorari.
Petitioner’s allegations—that the judge decided the case too hastily, made erroneous factual and legal conclusions, and improperly awarded damages—pertained to errors of judgment, not jurisdiction. A writ of certiorari corrects only errors of jurisdiction, not errors in the court’s evaluation of the evidence or application of law. The Court held that deciding a case promptly, within thirteen days in this instance, does not constitute grave abuse of discretion; it aligns with the duty to provide a speedy disposition of cases. Grave abuse of discretion implies a capricious, whimsical, or despotic exercise of judgment, which was not present. The petition, being an improper substitute for a lost appeal, was dismissed for lack of merit.