G.R. No. L-17337; October 30, 1964
FELISA REGALA, petitioner-appellant, vs. MARGARITA DE GUZMAN, and THE HON. ARSENIO H. LACSON, Mayor of the City of Manila, respondents-appellees.

FACTS

Petitioner Felisa Regala and respondent Margarita de Guzman were both stallholders in the Paco Market, Manila. In 1958, the Market Committee implemented a re-arrangement of stalls. Under the new plan, Regala was to be assigned stalls 1720-1722, while de Guzman was to be moved from her original stalls and offered a choice among four vacant corner stalls. De Guzman opposed this transfer. The Market Committee upheld the re-arrangement, but the City Mayor, Arsenio H. Lacson, ultimately issued an order on July 3, 1958, allowing de Guzman to remain in her former stalls. The Mayor found the forced transfer of de Guzman to be inequitable, noting that another stallholder in a similar situation was allowed to retain her position and that the Committee’s own member had submitted a conflicting report from an ocular inspection.
Regala filed a petition for certiorari with injunction in the Court of First Instance of Manila on July 11, 1959, alleging grave abuse of discretion by the Mayor. She sought to annul the Mayor’s order and to compel de Guzman to vacate the stalls. The lower court, on July 24, 1959, dismissed the petition without receiving evidence, holding that the matter was purely administrative and within the powers of the City Mayor. Regala appealed this dismissal.

ISSUE

Whether the lower court erred in dismissing the petition for certiorari without a hearing, and whether the City Mayor committed grave abuse of discretion in issuing his order allowing de Guzman to retain her stalls.

RULING

The Supreme Court affirmed the lower court’s dismissal. The Court held that the matter was administrative in nature and fell squarely within the discretionary powers of the City Mayor. The Revised Charter of Manila grants the Mayor immediate control over the executive functions of city departments, including the Market Committee. Furthermore, the City’s Market Code declares the Mayor’s decision on appeals from market officials as final, subject only to supervision by higher executive authorities (the President). The reasons provided by the Mayor for his decision—considerations of fairness, equity, and inconsistent application of the re-arrangement rules—did not constitute grave abuse of discretion. They reflected a legitimate exercise of his administrative judgment.
The Court also found that Regala failed to exhaust her administrative remedies, as she did not appeal the Mayor’s decision to the Office of the President. Regarding the procedural issue, the Supreme Court ruled that the lower court did not err in dismissing the petition without a full hearing. When, from the petition’s own allegations, it is apparent that the case lacks merit, a trial becomes an unnecessary formality. The petition itself failed to demonstrate any abuse of authority, thus justifying summary dismissal. Costs were imposed on the petitioner-appellant.