[8] A.L.

Ang Network vs Mondejar GR No 200804 22 January 2014

Topic: Certiorari in Small Claims

VERY SHORT DIGEST Facts: A.L. Ang Network, Inc. filed a complaint for sum of money under the Rule pf Procedure for Small Claims
Cases against respondent. The MTCC ruled in favour of respondent. A.L. Ang Network, Inc. file a petition for certiorari under Rule 65
before the RTC ascribing grave abuse of discretion on the part of MTCC in finding that they failed to establish with certainty
respondent’s obligation and in not ordering the respondent to pay the full amount to be collected. RTC dismissed the petition citing that
the petition was only filed to circumvent the non-appealable nature of small claims cases and 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.
Issue: WON RTC is correct in denying petitioner’s recourse under Rule 65 assailing the MTCC decision in the small claims case.
Decision: The petition is with merit.
The remedy of appeal is not allowed in the final nature of a small claims case decision. Nevertheless, the proscription on appeals in
small claims cases does not preclude the aggrieved party from filing a petition for certiorari under Rule 65.
A petition for certiorari, unlike an appeal, is an original action designed to correct only errors of jurisdiction and not of judgment. The
RTC 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.

FACTS
On 23 March 2011, petitioner filed a complaint for collection of sum of money under Rule of Procedure for Small Claims Cases before
the MTCC, seeking to collect from respondent the amount of P23, 111.71 which represented her unpaid water bills for the period of 1
June 2002 to 30 September 2005. Petitioner claimed that it was duly authorized to supply water to and collect payment therefor from
the homeowners of Regent Pearl Subdivision, one of whom is the respondent. Respondent assailed that she religiously paid the
monthly charges of P75.00. She claimed that the increased rate of P113.00 for every 10 cubic meter of water plus an additional P11.60
for every cubic meter thereafter was not valid because the petitioner unilaterally made the increase without informing the residents
therein which was stipulated in their agreement.

MTCC
The MTCC ruled in favour of the respondent. The petitioner can only charge the respondent the agreed flat rate for the period 1 June
2002 to 7 August 2003 since the Certificate of Public Convenience was only issued on the latter date. Respondent should be
considered to have fully paid. The MTCC disregarded the petitioner’s reliance on HLURB’s decision because it failed to prove that it
complied with the directive to inform the HLURB of the result of its consultation with the concerned homeowners as regards the rates to
be charged and the HLURB’s approval to such charges. Petitioner also failed to submit evidence showing the exact date when it
actually began imposing the NWRB approved rates and the formal agreement of the parties containing the terms and conditions
thereof, without which it cannot establish with certainty respondent’s obligation.

RTC
On a petition for certiorari under Rule 65 of the Rules of Court for grave abuse of discretion filed with the RTC, the petitioner assailed
that the MTCC disregarded petitioner’s reliance on the source of its authority to impose new water consumption rates. The RTC issued
a decision dismissing the petition, finding that the petition was only filed to circumvent the non-appealable nature of small claims cases
as provided in Section23 of the Rules of Procedure on Small Claims Cases. To this end, the RTC ruled that it cannot supplant the
decision of the MTCC with another decision directing respondent to pay petitioners a bigger sum than that which has been awarded.
Petitioner moved for reconsideration but was denied. Hence, this instant petition.

ISSUE Whether or not the RTC erred in dismissing petitioner’s recourse under Rule 65 of the RRC assailing the propriety of the
MTCC’s decision in the subject small claims case.

RULING Yes. The RTC erred in its decision.The petition for certiorari under Rule 65 of the RRC before the RTC was proper.
It is an essential requisite for the availability of the extraordinary remedies under the Rules in the absence of an appeal or any “plain,
speedy and adequate remedy” in the ordinary course of law.

In the case at bar, the first level courts are vested exclusive jurisdiction over small claims cases, certiorari petitions assailing
its dispositions should be filed to their corresponding RTCs. The SC held that the RTC was wrong in dismissing the said petition
on the ground that it was an improper remedy and, as such, the RTC case must be reinstated and remanded thereto for its proper
disposition.

Petition is granted. The RTC’s decision and resolution are reversed and set aside. RTC case is reinstated and the court a quo is
ordered to resolve the same with dispatch.