GR L 38062; (March, 1984) (Digest)
G.R. No. L-38062. March 6, 1984.
ALTO SALES CORPORATION, Petitioner, vs. JUDGE GUARDSON R. LOOD of the Court of First Instance of Rizal, Pasig Branch 6, and PHILIPPINE VIRGINIA TOBACCO ADMINISTRATION, Respondents.
FACTS
The case originated from a breach of contract dispute. In Civil Case No. 10001, Judge Andres Reyes, in a 1968 decision, ordered the Philippine Virginia Tobacco Administration (PVTA) to pay Alto Sales Corporation over thirty-two million pesos in damages. However, Judge Guardson R. Lood, presiding over the same case after a new trial was granted, rendered a 1974 judgment that reversed Judge Reyes’s decision. Judge Lood dismissed Alto’s complaint and absolved PVTA, finding that Alto breached the agreement by failing to secure a necessary export license from the Central Bank.
Alto appealed Judge Lood’s 1974 judgment to the Court of Appeals. Prior to that decision, and while the new trial was pending, Alto had also filed the instant 1974 petition for certiorari and mandamus before the Supreme Court. This petition sought to enforce Judge Reyes’s 1968 decision, contending it had become final and executory and that Judge Lood erred in granting a new trial. The Supreme Court had previously dismissed an earlier 1971 certiorari petition by Alto challenging the order for new trial as premature.
ISSUE
The primary procedural issue is whether the Supreme Court should directly resolve the factual and legal disputes in the certiorari petition and the consolidated appeal, or remand the case to the Appellate Court.
RULING
The Supreme Court resolved to remand the case to the then Intermediate Appellate Court. The legal logic is grounded in the proper allocation of judicial functions and the orderly administration of justice. Initially, the Court, with party consent, had consolidated Alto’s appeal from the Court of Appeals with this certiorari case. However, upon reconsideration, the Court set aside that consolidation order.
The Court emphasized that it is not a trier of facts. The case and the appeal were not submitted on a stipulation of facts. When facts are in dispute, the conclusion to be drawn from them is a question of law only if the facts are admitted. Here, the evidence was presented before two trial judges who reached diametrically opposed factual conclusions (Reyes for Alto, Lood for PVTA). Therefore, a factual determination is prerequisite. The Appellate Court’s fact-finding function should not be usurped.
Although the certiorari petition was arguably rendered moot by Alto’s own appeal of Judge Lood’s decision on the merits, the Supreme Court did not dismiss it outright. Instead, it endorsed the petition to the Appellate Court, which has concurrent jurisdiction to resolve such special civil actions. The Appellate Court is directed to decide the appeal and the related certiorari issues together, adjudicating all factual and legal questions, including the validity of the order granting a new trial. This promotes judicial efficiency by having the court that reviews the evidence resolve all intertwined issues.
