G.R. No. 199501 ; March 6, 2013
Republic of the Philippines, represented by the Regional Executive Director, DENR Region III, Petitioner, vs. Heirs of Enrique Oribello, Jr. and the Register of Deeds of Olongapo City, Respondents.

FACTS

The petitioner, Republic of the Philippines, filed a complaint for reversion and cancellation of Original Certificate of Title (OCT) No. P-5004 issued to Enrique Oribello, Jr., alleging fraud and misrepresentation in the approval of his Miscellaneous Sales Application over a parcel of land in Olongapo City. The DENR investigation found that the Land Inspector submitted a false report stating Oribello was the sole occupant, when in fact, other claimants were present. The reversion case was consolidated with a separate recovery of possession suit filed by Oribello.
During trial, the petitioner repeatedly failed to appear on scheduled hearing dates despite warnings from the trial court. In an Order dated July 25, 1997, the court deemed the Republic to have abandoned its case. The trial proceeded with the private parties. Later, the trial court dismissed the consolidated cases without prejudice due to the death of Oribello and his counsel without substitution. Upon petitioner’s motion for reconsideration, the court clarified that the dismissal pertained only to the recovery of possession case, but it subsequently issued an Order on March 31, 2008, definitively dismissing the reversion case, citing the July 25, 1997 Order which had already deemed the petitioner to have abandoned its action.

ISSUE

Whether the trial court committed grave abuse of discretion in dismissing the reversion case.

RULING

No, the trial court did not commit grave abuse of discretion. The dismissal was a final order that disposed of the case, not a mere interlocutory one, and was therefore not subject to a petition for certiorari under Rule 65 but to an ordinary appeal. The petitioner erroneously filed a petition for certiorari instead of a timely appeal. The legal logic is grounded in the distinction between final and interlocutory orders under the Rules of Court. A final order terminates the litigation, while an interlocutory order does not. The March 31, 2008 Order, which invoked the earlier abandonment ruling, conclusively dismissed the reversion suit. Since the petitioner’s remedy was an appeal, which it did not pursue within the reglementary period, the certiorari petition was an improper substitute. The Court emphasized that certiorari is not a remedy for errors of judgment but for jurisdictional errors or grave abuse of discretion amounting to lack of jurisdiction. The trial court’s act of dismissing the case for the petitioner’s failure to prosecute, after due warning, was an exercise of its sound discretion, not a capricious or whimsical act constituting grave abuse.