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ERLINDA REYES v. JUDGE BELEN B. ORTIZ

FACTS:

The consolidated petitions for declaratory relief, certiorari, and prohibition involve various ejectment cases filed before the Metropolitan Trial Court (MeTC), Caloocan City and the Regional Trial Court (RTC), Caloocan City. The subject matter of these cases is the Tala Estate, an area of 7,007.9515 hectares more or less located between Caloocan City and Quezon City. In G.R. No. 137794, respondents Segundo Bautista and the Perl spouses sought to oust Erlinda Reyes, the Matienzo spouses, and Sergio Abejero, who are occupants of separate home lots in Camarin, Caloocan City. Civil Case No. C-17725, a complaint for Recovery of Possession and/or Ownership of Real Property, was filed by Bautista against the Matienzo spouses. Another related action, a complaint for Annulment of Title/Reversion, was filed by the Republic of the Philippines against Biyaya Corporation and others involving the Tala Estate. A preliminary injunction was issued by the Quezon City RTC in the annulment/reversion case, freezing all ejectment cases involving the Tala Estate pending in the MeTCs of Quezon City and Caloocan City. In G.R. No. 149664, Spouses Perl filed ejectment cases against Erlinda Reyes and Sergio Abejero in the Caloocan City MeTC. These cases were consolidated, and in the RTC, Erlinda Reyes appealed the MeTC decision. Respondent-spouses Perl moved for the execution of the MeTC decision pending appeal. Petitioner Erlinda Reyes and company filed a motion to suspend the proceedings in the RTC, which was temporarily restrained by the Court.

In this case, G.R. No. 149664 involves four separate ejectment complaints against the petitioners, who are members of Alyansa Ng Mga Naninirahan Sa Tala Friar Lands (ALNATFRAL), an intervenor in the Reversion case. The ejectment cases were filed in Camarin, Caloocan City and within the Tala Estate. The petitioners invoked the injunction order issued by the Quezon City RTC in the Annulment/Reversion case in seeking the dismissal or suspension of the ejectment cases. However, their motions for suspension were dismissed and judgments were rendered in the ejectment cases. Petitioners then filed a motion for consolidation to consolidate G.R. No. 149664 with another case. The motion was granted, but the petitioners later filed a motion to withdraw and dismiss G.R. No. 149664, stating that a decision in the Annulment/Reversion case had already been issued. The Court granted the motion to withdraw and considered G.R. No. 149664 closed and terminated. The remaining case to be resolved is G.R. No. 137794. The petitioners argue that the Caloocan City MeTC and RTC were divested of jurisdiction over the ejectment and Recovery cases, respectively, due to the jurisdiction acquired by the Quezon City RTC. They claim that the refusal of the MeTC to suspend the ejectment cases and the Caloocan City RTC's noncompliance with the injunction constitute lack of or excess of jurisdiction. The Office of the Solicitor General supports the petitioners' position. Respondent Segundo Bautista argues that the petitioners resorted to the wrong remedy and that direct resort to the Supreme Court violates the rule on the hierarchy of courts. He maintains that the Caloocan City RTC had jurisdiction and was not bound by the injunction issued by the Quezon City RTC.

Petitioner Matienzo filed a petition for declaratory relief seeking the nullification of certain provisions of Republic Act No. 9167, which amended certain provisions of the Philippine Mining Act of 1995. Petitioners argued that the said provisions violated various constitutional rights, specifically the equal protection clause and the due process clause. The Regional Trial Court (RTC) dismissed the petition, ruling that it was a collateral attack on the constitutionality of the law and that the doctrine of hierarchy of courts should be observed. The Court of Appeals (CA) affirmed the RTC's decision. Petitioners then elevated the case to the Supreme Court, arguing that the CA erred in affirming the dismissal of their petition. They claimed that the CA should have exercised its power of concurrent jurisdiction since there was no other adequate remedy available.

ISSUES:

  1. Whether the petition for declaratory relief should have been filed with the Court of Appeals instead of the Supreme Court.

  2. Whether the Caloocan City RTC erred in not suspending the proceedings in the Recovery case.

  3. Whether the petitioners should have filed a special civil action on certiorari instead of a petition for declaratory relief.

  4. Whether exceptional and compelling circumstances exist to warrant direct resort to the Supreme Court.

  5. Can a court issue an injunction against the judgments or orders of a co-equal and coordinate court of concurrent jurisdiction?

  6. Can a pending civil action for ownership suspend an ejectment proceeding?

RULING:

  1. Yes. The petition for declaratory relief should have been filed with the Court of Appeals instead of the Supreme Court. The petitioner failed to state exceptional and compelling circumstances that would justify the exercise of the Supreme Court's primary jurisdiction.

  2. No. The Caloocan City RTC did not err in not suspending the proceedings in the Recovery case as the injunction issued by the Quezon City RTC only applied to the MeTCs of Quezon City and Caloocan City.

  3. Yes. The petitioners should have filed a special civil action on certiorari under Rule 65 with the Court of Appeals from the denial of their motion by the trial court. The necessity of filing such petition is dictated by the principle of the hierarchy of courts. The Court emphasized that taking a procedural shortcut is not allowed, and there is no statutory or jurisprudential basis for conferring original and exclusive jurisdiction to the Supreme Court over declaratory relief cases. The proper remedy in this case is a special civil action on certiorari.

  4. No. The Court held that petitioners failed to show exceptional and compelling circumstances to warrant direct resort to the Supreme Court. They did not present a compelling reason for bypassing the proper courts. The Court emphasized that it will not entertain direct resort except when the redress sought cannot be obtained in the proper courts or when exceptional and compelling circumstances justify a recourse to the Supreme Court’s primary jurisdiction.

  5. No, a court does not have the power to interfere by injunction with the judgments or orders of a co-equal and coordinate court of concurrent jurisdiction. The various trial courts of a province or city, having the same or equal authority, are not permitted to interfere with their respective cases, much less with their orders or judgments. Interference by one court on the proceedings and processes of another is prohibited by law and would lead to confusion and hamper the administration of justice.

  6. No, a pending civil action for ownership, such as an annulment of title, does not automatically suspend an ejectment proceeding. The issue in an ejectment case is possession, while in an annulment case the issue is ownership. An ejectment case can be tried independently of an annulment case. There are exceptions to this rule, but the petitioners failed to justify that their case falls within any of these exceptions.

PRINCIPLES:

  • Declaratory relief is a special civil action to determine any question of construction or validity arising under a deed, will, contract, or other written instrument, or a statute, ordinance, executive order, or regulation, and to obtain a declaration of rights and duties thereunder.

  • Abstention is the principle that courts should not interfere in cases pending before other tribunals of competent jurisdiction, absent exceptional and compelling circumstances.

  • Court orders or decisions cannot be made the subject matter of a declaratory relief.

  • Hierarchy of Courts – Petitioners should file the appropriate petition depending on the nature of their case, following the hierarchy of courts.

  • Procedural Shortcut – Parties should not take a procedural shortcut and must follow the prescribed remedies under the rules of court.

  • Exclusive Jurisdiction of Supreme Court – The Supreme Court does not have original and exclusive jurisdiction over declaratory relief cases.

  • Exceptional and Compelling Circumstances – Direct resort to the Supreme Court is allowed only when there are exceptional and compelling circumstances that warrant such recourse.

  • Courts of concurrent jurisdiction should not interfere with their respective cases and orders

  • A pending civil action for ownership does not automatically suspend an ejectment proceeding, as the issues involved are different