GR 170096; (March, 2006) (Digest)
G.R. No. 170096-97, March 3, 2006
RICARDO SANTOS and PAULA SANTOS WONG, Petitioners, vs. ILUMINADA CRUZ, represented by Attorney-in-fact GLORIA ISRAEL, JUDGE FRANCISCO LINDO, MeTC, Branch 55, Malabon City, Respondents.
FACTS
Respondent Iluminada Cruz filed two ejectment cases against petitioners Ricardo Santos and Paula Santos Wong, alleging they occupied portions of her land in Malabon City without her consent and built structures thereon. She claimed they were allowed to stay as relatives free of charge on condition to vacate upon demand, which they refused. Petitioners admitted Cruz’s ownership but defended their possession, with Santos claiming a 1978 Deed of Absolute Sale for a portion and Wong citing a 1976 Subdivision Agreement with Contract of Sale for another portion. The Metropolitan Trial Court (MeTC) dismissed the complaints for failure of Cruz to prove her cause by preponderance of evidence. On appeal, the Regional Trial Court (RTC) reversed the MeTC, ordering petitioners to vacate, pay monthly compensation for use, and pay attorney’s fees.
ISSUE
Whether the Supreme Court should grant the petition for certiorari under Rule 65 assailing the RTC Decision.
RULING
The Supreme Court dismissed the petition for insufficiency of form and substance. The legal logic is anchored on strict procedural compliance for extraordinary writs. Petitioners filed the certiorari petition directly with the Supreme Court without first filing a motion for reconsideration of the RTC Decision, a procedural prerequisite to allow the lower court to correct its own error. They failed to show a concrete, compelling reason to dispense with this requirement. Moreover, they disregarded the doctrine of hierarchy of courts, as a petition for certiorari against an RTC decision should have been filed with the Court of Appeals, not directly with the Supreme Court. Concurrent jurisdiction does not permit unrestricted forum choice; direct recourse is allowed only if redress is unattainable in lower courts under exceptional circumstances, which petitioners did not allege. The petition also suffered from formal infirmities, as earlier flagged by the Court in a resolution, including issues with the certification against forum shopping and proof of service. Thus, for non-compliance with procedural rules and absence of justification for bypassing the hierarchy of courts, the petition was dismissed and the RTC Decision affirmed.