G.R. No. 203142 , August 26, 2015
THE PHILIPPINE PORTS AUTHORITY (PPA), PETITIONER, VS. COALITION OF PPA OFFICERS AND EMPLOYEES, REPRESENTED BY HECTOR E. MIOLE, ET AL., RESPONDENTS.

FACTS

The Philippine Ports Authority (PPA), a government-owned and controlled corporation, discontinued the payment of Cost of Living Allowance (COLA) and Amelioration Allowance (AA) to its employees on March 16, 1999, pursuant to Section 4 of DBM Corporate Compensation Circular No. 10 and the ruling in Philippine Ports Authority (PPA) Employees Hired After July 1, 1989 v. Commission on Audit. In 2008, the respondent Coalition of PPA Officers and Employees filed an Amended Petition for Mandamus with Damages before the Regional Trial Court (RTC) of Cebu City, seeking to compel PPA to pay these allowances, claiming they were withheld starting July 15, 1999. PPA, in its Amended Answer, raised several affirmative defenses including lack of legal standing of the coalition, litis pendentia, res judicata, lack of cause of action (as the allowances were integrated into standardized salaries effective March 16, 1999), and that mandamus would not lie. The RTC, after reviewing the pleadings and memoranda on the affirmative defenses, issued an Order stating it could render judgment based on the pleadings without further hearings and directed the parties to submit memoranda. PPA filed a Motion for Reconsideration, arguing a hearing was necessary to present evidence on factual issues like the coalition’s membership and to authenticate documents. The RTC denied the motion, holding the primary issue was legal—whether PPA could be compelled by mandamus to perform a duty enjoined by law (RA 6758)—and that other issues were incidental. PPA then filed a Petition for Certiorari with the Court of Appeals (CA), alleging the RTC committed grave abuse of discretion in not conducting a hearing. The CA dismissed the petition, ruling that under Section 8 of Rule 65 and Section 6 of Rule 16 of the Rules of Court, holding a hearing on affirmative defenses is discretionary on the trial court, and the RTC acted within its discretion to expedite the mandamus suit.

ISSUE

Whether the Court of Appeals erred in ruling that the Regional Trial Court did not commit grave abuse of discretion in issuing the June 27, 2008 and September 5, 2008 Orders, which denied petitioner PPA’s motion for a preliminary hearing on its affirmative defenses and proceeded to decide the mandamus case based on the pleadings.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ Decision. The Court held that the RTC did not commit grave abuse of discretion. Under Section 8, Rule 65 of the 1997 Rules of Civil Procedure, after the required pleadings are filed, the court “may hear the case or require the parties to submit memoranda.” The use of “may” indicates that conducting a hearing is discretionary, not mandatory. Similarly, Section 6, Rule 16 provides that a preliminary hearing on affirmative defenses pleaded in an answer is “in the discretion of the court.” The RTC validly exercised this discretion to expedite the disposition of the mandamus case, as it determined the principal issue—whether mandamus lies to compel PPA to pay allowances allegedly integrated into salaries—was a legal question resolvable based on the pleadings. The Court found no capricious, whimsical, or arbitrary exercise of judgment by the RTC that would constitute grave abuse of discretion. The special civil action for certiorari is not intended to correct errors of judgment but only errors of jurisdiction. Since the RTC acted within its jurisdiction and discretion, its orders were not subject to nullification via certiorari.