G.R. No. 213039. November 27, 2017
POLYTECHNIC UNIVERSITY OF THE PHILIPPINES, Petitioner, vs. NATIONAL DEVELOPMENT COMPANY, Respondent.

FACTS

This case involves the execution of a final Supreme Court decision in G.R. Nos. 183612 and 184260 (March 15, 2010), which affirmed Golden Horizon Realty Corporation’s (GHRC) right to purchase specific leased portions of the NDC Compound in Sta. Mesa, Manila, from the National Development Company (NDC). The Court ordered petitioner Polytechnic University of the Philippines (PUP), in whose name the property was titled following a transfer from the National Government, to reconvey the subject lots to GHRC upon payment. The decision became final and executory. For execution, GHRC deposited the purchase price with the Clerk of Court.
During execution proceedings before the Regional Trial Court (RTC), a dispute arose between NDC and PUP over who was entitled to receive the purchase price deposited by GHRC. The RTC, in its February 2, 2012 Resolution, ordered the amount to be released to NDC, not PUP. PUP filed a petition for certiorari and prohibition under Rule 65 before the Court of Appeals (CA), challenging this RTC order. The CA dismissed PUP’s petition, finding no grave abuse of discretion by the RTC. PUP elevated the case via a Rule 45 petition.

ISSUE

Whether the Court of Appeals erred in dismissing PUP’s Rule 65 petition and in upholding the RTC’s order directing the release of the purchase price to NDC.

RULING

The Supreme Court denied the petition and affirmed the CA. The core legal logic rests on the nature and proper scope of a petition for certiorari under Rule 65. Such a petition is not a remedy for correcting errors of judgment but is only available to correct errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction. Grave abuse of discretion exists when the act is performed in a capricious, whimsical, arbitrary, or despotic manner, equivalent to an evasion of a positive duty.
The RTC’s order to release the funds to NDC was a logical and legal implementation of the final Supreme Court decision. That decision recognized and enforced GHRC’s contractual right to purchase the property from its original lessor, NDC. The payment from GHRC was, in substance, the purchase price for NDC’s property. PUP’s interest arose solely from a subsequent government transfer, but this did not extinguish NDC’s original obligation to GHRC or its correlative right to receive payment for the sale of its asset. The RTC’s interpretation and execution of the final judgment were within its jurisdiction and discretion. PUP failed to demonstrate that the RTC’s act was tainted with grave abuse of discretion; it merely showed a disagreement with the RTC’s legal interpretation, which is an error of judgment, not correctible by certiorari. Thus, the CA correctly found no basis to grant the extraordinary writ.