G.R. No. L-25024 March 30, 1970
TEODORO C. SANTIAGO, JR., Minor, Represented by his Mother, Mrs. Angelita C. Santiago, petitioner-appellant, vs. MISS JUANITA BAUTISTA, ROSALINDA ALPAS, REBECCA MATUGAS, MILKITA INAMAC, ROMEO AGUSTIN, AIDA CAMINO, LUNA SARMAGO, AURORA LORENA, SOLEDAD FRANCISCO and MR. FLOR MARCELO, respondents-appellees.

FACTS

Petitioner-appellant Teodoro C. Santiago, Jr., a Grade Six pupil at Sero Elementary School in Cotabato City, was ranked third honor by the school’s “Committee On The Rating Of Students For Honor” for the school year 1964-1965. Three days before the scheduled graduation exercises on May 21, 1965, Santiago, represented by his mother and with his father as counsel, filed a civil case for certiorari, injunction, and damages in the Court of First Instance of Cotabato against the committee members (teachers), the School Principal, the District Supervisor, and the Academic Supervisor. The complaint alleged grave abuse of discretion and irregularities in the selection process, including that the committee was illegally composed (allegedly violating the Service Manual for Teachers by including only Grade VI teachers instead of Grades V and VI teachers), that a rival pupil was unfairly tutored by a teacher, that final ratings were altered, that improper district examinations were considered, and that there was a pattern of discrimination against him. The lower court denied the prayer for a preliminary injunction, and the graduation proceeded with the disputed rankings. Respondents filed a motion to dismiss the case, which the lower court granted, holding that the complaint stated no cause of action. The court found that the petition for certiorari violated Rule 65, Section 1 of the Rules of Court for not being accompanied by a certified true copy of the judgment or order complained of and relevant documents, that administrative remedies were not exhausted, and that the allegations constituted errors in judgment rather than grave abuse of discretion. Petitioner appealed the order of dismissal.

ISSUE

Whether the Court of First Instance correctly dismissed the petition for certiorari on the ground that it states no cause of action, due to non-compliance with procedural requirements for certiorari, failure to exhaust administrative remedies, and lack of showing of grave abuse of discretion.

RULING

Yes, the dismissal was proper. The Supreme Court affirmed the order of the lower court. The petition for certiorari was fatally defective for failure to comply with the mandatory requirement of Rule 65, Section 1 of the Rules of Court, which requires that the petition be accompanied by a certified true copy of the judgment or order subject thereof, together with copies of all relevant pleadings and documents. The appellant failed to attach the committee’s decision on the ranking, the Service Manual for Teachers, altered grading sheets, or the altered Grade I certificate mentioned in the petition. This violation rendered the petition indefinite and uncertain. Given this conclusion, the Supreme Court found it unnecessary to rule on the other grounds for dismissal, such as failure to exhaust administrative remedies or the substantive issue of grave abuse of discretion. The appealed judgment was affirmed, with costs against the appellant.