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    AL Ang Network Inc. vs. Mondejar

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    MAC
    The document discusses a case where a petitioner filed a petition for certiorari under Rule 65 to assail a small claims case decision by the Metropolitan Trial Court. The Regional Trial Court dismissed the petition, finding it was an improper remedy. The Supreme Court held that the Regional Trial Court erred in dismissing the petition, as certiorari is a proper remedy to challenge jurisdictional errors in a small claims case decision, being that appeals are prohibited. The case was remanded back to the Regional Trial Court for proper disposition.

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    AL Ang Network Inc. vs. Mondejar

    Uploaded by

    MAC
    22 views1 page
    The document discusses a case where a petitioner filed a petition for certiorari under Rule 65 to assail a small claims case decision by the Metropolitan Trial Court. The Regional Trial Court dismissed the petition, finding it was an improper remedy. The Supreme Court held that the Regional Trial Court erred in dismissing the petition, as certiorari is a proper remedy to challenge jurisdictional errors in a small claims case decision, being that appeals are prohibited. The case was remanded back to the Regional Trial Court for proper disposition.

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    The document discusses a case where a petitioner filed a petition for certiorari under Rule 65 to assail a small claims case decision by the Metropolitan Trial Court. The Regional Trial Court dismissed the petition, finding it was an improper remedy. The Supreme Court held that the Regional Trial Court erred in dismissing the petition, as certiorari is a proper remedy to challenge jurisdictional errors in a small claims case decision, being that appeals are prohibited. The case was remanded back to the Regional Trial Court for proper disposition.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    22 views1 page

    AL Ang Network Inc. vs. Mondejar

    Uploaded by

    MAC
    The document discusses a case where a petitioner filed a petition for certiorari under Rule 65 to assail a small claims case decision by the Metropolitan Trial Court. The Regional Trial Court dismissed the petition, finding it was an improper remedy. The Supreme Court held that the Regional Trial Court erred in dismissing the petition, as certiorari is a proper remedy to challenge jurisdictional errors in a small claims case decision, being that appeals are prohibited. The case was remanded back to the Regional Trial Court for proper disposition.

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    AL Ang Network Inc. vs.

    Mondejar
    G.R. No. 200804 January 22, 2014

    Issue: Whether or not the RTC erred in dismissing petitioner’s recourse under Rule 65 of the Rules of
    Court assailing the propriety of the MTCC Decision in the subject small claims case.

    Held: Yes.

    Section 23 of the Rule of Procedure for Small Claims Cases states that:

    SEC. 23. Decision. — After the hearing, the court shall render its decision on the same day,
    based on the facts established by the evidence (Form 13-SCC). The decision shall
    immediately be entered by the Clerk of Court in the court docket for civil cases and a copy
    thereof forthwith served on the parties.

    The decision shall be final and unappealable.

    Considering the final nature of a small claims case decision under the above-stated rule, the
    remedy of appeal is not allowed, and the prevailing party may, thus, immediately move for its execution.
    Nevertheless, the proscription on appeals in small claims cases, similar to other proceedings where
    appeal is not an available remedy, does not preclude the aggrieved party from filing a petition for certiorari
    under Rule 65 of the Rules of Court.

    Although Section 1, Rule 65 of the Rules of Court provides that the special civil action of certiorari
    may only be invoked when "there is no appeal, nor any plain, speedy and adequate remedy in the course
    of law," this rule is not without exception. The availability of the ordinary course of appeal does not
    constitute sufficient ground to prevent a party from making use of the extraordinary remedy of certiorari
    where appeal is not an adequate remedy or equally beneficial, speedy and sufficient. It is the inadequacy
    – not the mere absence – of all other legal remedies and the danger of failure of justice without the writ
    that usually determines the propriety of certiorari.

    Here, petitioner filed a petition for certiorari under Rule 65 of the Rules of Court before the RTC,
    ascribing grave abuse of discretion on the part of the MTCC in finding that it (petitioner) failed to establish
    with certainty respondent’s obligation, and in not ordering the latter to pay the full amount sought to be
    collected. The RTC ruled that it cannot supplant the decision of the MTCC with another decision directing
    respondent to pay petitioner a bigger sum than that which has been awarded.

    Verily, a petition for certiorari, unlike an appeal, is an original action designed to correct only
    errors of jurisdiction and not of judgment. Owing to its nature, it is therefore incumbent upon petitioner to
    establish that jurisdictional errors tainted the MTCC Decision. The RTC, in turn, could either grant or
    dismiss the petition based on an evaluation of whether or not the MTCC gravely abused its discretion by
    capriciously, whimsically, or arbitrarily disregarding evidence that is material to the controversy. The Court
    thus finds that petitioner correctly availed of the remedy of certiorari to assail the propriety of the MTCC
    Decision in the subject small claims case, contrary to the RTC’s ruling.

    Considering that small claims cases are exclusively within the jurisdiction of the Metropolitan Trial
    Courts, Municipal Trial Courts in Cities, Municipal Trial Courts, and Municipal Circuit Trial Courts, certiorari
    petitions assailing its dispositions should be filed before their corresponding Regional Trial Courts. This
    petitioner complied with when it instituted its petition for certiorari before the RTC which, as previously
    mentioned, has jurisdiction over the same. In fine, the RTC erred in dismissing the said petition on the
    ground that it was an improper remedy, and, as such, RTC Case No. 11-13833 must be reinstated and
    remanded thereto for its proper disposition.

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