GR 182484; (June, 2008) (Digest)
G.R. No. 182484; June 17, 2008
DANIEL MASANGKAY TAPUZ, ET AL., petitioners, vs. HON. JUDGE ELMO DEL ROSARIO, ET AL., respondents.
FACTS
The private respondents, Spouses Sanson, filed a complaint for forcible entry and damages against the petitioners before the Municipal Circuit Trial Court (MCTC). They alleged they were the registered owners and prior possessors of a parcel of land in Boracay, and that the petitioners, armed and with a large group, forcibly entered the land in April 2006, built structures, and ousted them. The petitioners, in their answer, claimed they were the actual and prior possessors as indigenous settlers and asserted the respondents’ title was spurious.
The MCTC ruled in favor of the Sansons, finding they had prior possession since 1993, evidenced by a perimeter fence they constructed, and that the petitioners’ entry in 2006 was by force. The petitioners appealed to the RTC, which affirmed the MCTC decision. The RTC subsequently issued a writ of execution. The petitioners then filed a petition for certiorari with the Court of Appeals (CA), which was dismissed for procedural defects. They then filed the present petition with the Supreme Court, combining a petition for certiorari under Rule 65 with petitions for the writs of Amparo and Habeas Data.
ISSUE
Whether the Supreme Court should give due course to the consolidated petition for certiorari and for the issuance of the writs of amparo and habeas data.
RULING
The Supreme Court dismissed the petition. On the petition for certiorari, the Court found it insufficient in form and substance. The petitioners failed to comply with procedural requirements, such as attaching a certified true copy of the CA decision and properly verifying their statement of material dates. More critically, they did not establish that the RTC acted without or in excess of jurisdiction or with grave abuse of discretion. The RTC’s affirmance of the MCTC’s factual finding of prior possession in a forcible entry case is beyond the scope of certiorari, as no jurisdictional error was demonstrated.
Regarding the writs of amparo and habeas data, the Court held they were utterly misplaced. The writ of amparo is a remedy for extralegal killings and enforced disappearances, or threats thereof. The writ of habeas data is designed to protect a person’s right to privacy concerning personal information. The core of the case is a dispute over possession and title to land, a purely civil matter. The allegations of threats and harassment by the respondents and police, even if true, do not constitute the type of extraordinary threats to life, liberty, or security that justify these special writs. The proper remedies for the petitioners’ grievances, if any, lie in separate civil or criminal actions, not in the writs of amparo or habeas data.