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SANTIAGO LAND DEVELOPMENT COMPANY v. CA

FACTS:

Respondent Komatsu Industries failed to pay its indebtedness to the Philippine National Bank (PNB) amounting to P27,000,000. As a result, PNB initiated foreclosure proceedings on the 18,000 square meter mortgaged property belonging to Komatsu Industries. Komatsu Industries filed a petition seeking to prevent the foreclosure, but the property was eventually foreclosed by PNB. Komatsu Industries then filed an amended petition to declare nullity of the foreclosure sale. During the pendency of the case, petitioner Santiago Land Development Corporation (SLDC) purchased the subject property and intervened in the case. SLDC later served written interrogatories on Komatsu Industries' counsel, which were not answered. SLDC filed a motion to dismiss the case based on Komatsu Industries' failure to answer the interrogatories.

ISSUES:

  1. Whether the service of written interrogatories on respondent Komatsu Industries' counsel, rather than directly on its officers, constituted valid service under the Rules of Court.

  2. Whether the Regional Trial Court committed grave abuse of discretion in denying the petitioner Santiago Land Development Corporation's (SLDC) motion to dismiss the civil case for non-response to the interrogatories, warranting a review by certiorari.

RULING:

  1. The Court of Appeals held that there was a valid service of the written interrogatories on respondent Komatsu Industries because they were served on its counsel of record. This service was deemed proper under the rules.

  2. The Court of Appeals found that while there might have been an error of judgment by the Regional Trial Court in denying the motion to dismiss based on SLDC's interpretation of the rules, this did not constitute grave abuse of discretion. The court emphasized that certiorari is intended to correct defects of jurisdiction only and is not a remedy for errors of procedure or improper findings. Therefore, the trial court's action in denying the motion to dismiss does not qualify as a grave abuse of discretion correctable by certiorari as it was not an exercise of power that was capricious, arbitrary, or whimsical.

As such, Santiago Land Development Corporation’s petition for review by certiorari was dismissed by the Supreme Court for lack of merit, affirming the decision of the Court of Appeals.

PRINCIPLES:

  1. Valid service of written interrogatories can be achieved when they are served on the counsel of record, not necessarily directly on the party or its officers.

  2. Errors of judgment regarding procedural rules by a trial court do not constitute grave abuse of discretion unless they involve jurisdictional defects.

  3. Certiorari under Philippine procedural law is used solely to correct errors of jurisdiction and not to correct errors of procedure or mistakes in the judge’s findings and conclusions.

  4. A trial court has discretionary power to dismiss an action according to its assessment of the circumstances, which should not be reversed on appeal in the absence of a clear abuse of that discretion.

  5. Denial of a motion to dismiss, being interlocutory, generally cannot be the subject of an appeal or certiorari until a final judgment or order has been rendered.