MUNICIPALITY OF SAN FERNANDO v. JUDGE ROMEO N. FIRME

FACTS:

On December 16, 1965, a collision occurred involving a passenger jeepney, a gravel and sand truck, and a dump truck owned by the Municipality of San Fernando, La Union and driven by Alfredo Bislig. As a result, several passengers of the jeepney, including Laureano Baniña Sr., died while others sustained injuries. Private respondents, heirs of Laureano Baniña Sr., filed a complaint for damages against the owner and driver of the passenger jeepney. The defendants filed a Third Party Complaint against the Municipality of San Fernando and Bislig. The case was transferred to Branch IV, presided over by respondent judge, and docketed as Civil Case No. 107-Bg. The private respondents later amended their complaint to include the petitioner and Bislig as defendants. The petitioner raised affirmative defenses disputing the cause of action and the liability of the State. However, respondent judge issued various orders during the proceedings, and on October 10, 1979, a decision was rendered, ordering the petitioner and Bislig to pay the plaintiffs for funeral expenses, lost expected earnings, moral damages, and attorney's fees. The complaint against the owner and driver of the passenger jeepney was dismissed. Petitioner filed a motion for reconsideration and new trial, but it was denied. Respondent judge issued an order directing the petitioner to elevate the matter to a higher court if they wish to pursue it. Petitioner filed this petition for certiorari to nullify or modify the proceedings and orders issued by respondent judge.

ISSUES:

  1. Whether or not the respondent judge committed grave abuse of discretion amounting to excess of jurisdiction in issuing the orders and rendering a decision.

  2. Whether or not the decision of the trial court is appealable.

RULING:

  1. The Supreme Court held that the respondent judge did not commit grave abuse of discretion in issuing the orders and rendering a decision. The Court noted that the orders and decision were issued within the respondent judge's jurisdiction and were based on the evidence and arguments presented during the proceedings.

  2. The Court ruled that the decision of the trial court is appealable. The Court stated that while appeal may not be the most speedy and adequate remedy in this case, it is the proper recourse for the petitioner to question the decision of the trial court.

PRINCIPLES:

  • Grave abuse of discretion amounting to excess of jurisdiction can only be attributed to a judge when there is capricious, whimsical, or arbitrary exercise of judgment as is equivalent to lack of jurisdiction. (Ruling on issue 1)

  • Decisions of trial courts are generally appealable. (Ruling on issue 2)