G.R. No. 249080 , September 15, 2021
David Nacionales, Petitioner, vs. Hon. Leah Garnet G. Solde-Annogui, in her capacity as Presiding Judge, and Pera-Multipurpose Cooperative, represented by Jay Bonghanoy, Respondents.

FACTS

The case originated from a small claims action for Collection of Sum of Money and Damages filed by Pera Multipurpose Cooperative (respondent) against David Nacionales (petitioner). Respondent alleged it granted petitioner a loan of P67,700.00 payable in 24 months at 24% interest per annum. Petitioner defaulted, resulting in an outstanding obligation of P49,436.46 as of March 29, 2019. After an unheeded demand, respondent filed the small claims case. Petitioner received the Summons and Statement of Claim but failed to submit a response. On July 3, 2019, both parties appeared but failed to settle. The Municipal Circuit Trial Court (MCTC) proceeded, heard the case, and partly granted respondent’s claim, ordering petitioner to pay P36,647.00 as principal, P7,447.00 as interest, plus 24% per annum interest from the decision’s finality until fully paid, and costs. Petitioner filed a Petition for Certiorari and Mandamus directly with the Supreme Court, alleging: (1) the loan computation violated the Truth in Lending Act due to a prepaid interest deduction; (2) he was denied due process as the judge was not present at the hearing, with only the Clerk of Court attending; and (3) the imposition of 24% interest after finality was incorrect. Judge Solde-Annogui countered that she was present, petitioner walked out when advised to enter her chambers, and the contract terms were understood. Respondent argued the petition violated the hierarchy of courts and raised evidentiary issues.

ISSUE

Whether the petition should be dismissed for violating the policy on hierarchy of courts and, alternatively, whether petitioner is entitled to the extraordinary writ of certiorari.

RULING

The Supreme Court DISMISSED the petition. The Court held that petitioner violated the policy on hierarchy of courts by filing the petition directly with the Supreme Court instead of with the Regional Trial Court (RTC), without presenting any special, important, or compelling reason to justify such direct filing. The Court emphasized that decisions in small claims cases are final and unappealable, but an aggrieved party may file a petition for certiorari under Rule 65. However, such petitions against first-level courts should be filed with the RTC, in accordance with the hierarchy of courts. The Court’s original jurisdiction to issue writs is shared with lower courts, and direct invocation is allowed only for special reasons, which petitioner failed to show. Alternatively, even disregarding the hierarchy issue, petitioner failed to establish that the MCTC committed jurisdictional error warranting certiorari, as his petition essentially sought a review of factual matters, which is not the function of a certiorari proceeding. The Court is not a trier of facts. Petitioner was directed to pay the cost of suit.