Rayos v. Manila

G.R. No. 196063 (December 14, 2011)

Supreme Court upheld Manila's Ordinance No. 7949, citing improper petition procedures and non-appealability.

Facts:

The case originated from a complaint for eminent domain filed by the City of Manila against several defendants, including Remedios V. De Caronongan and others, concerning a parcel of land co-owned by them, covered by Transfer Certificate of Title No. 227512, with an area of 1,182.20 square meters. The City of Manila, through Ordinance No. 7949, sought to acquire the property either by expropriation or negotiation, offering a purchase price of P1,000.00 per square meter. The defendants expressed their willingness to sell but demanded a significantly higher price of P50,000.00 per square meter, claiming it was the fair market value.

During the proceedings, one of the defendants, Laureano M. Reyes, passed away, and his son, Manuel A. Rayos, substituted him as a party. Additionally, Orlando A. Rayos intervened, and Fe A. Rayos Dela Paz was added as a defendant. On December 7, 2009, the petitioners filed a Motion to Dismiss the case, arguing that Ordinance No. 7949 was unconstitutional and that precedents from the cases of Lagcao v. Labra and Jesus Is Lord Christian School Foundation, Inc. v. Municipality of Pasig were applicable.

The Regional Trial Court of Manila denied the motion to dismiss on March 11, 2010, stating that the petitioners failed to demonstrate compelling reasons for the application of the doctrine of stare decisis. The court emphasized the need for the trial to continue to determine just compensation. The petitioners subsequently filed a motion for reconsideration, which was also denied on January 6, 2011.

Legal Issues:

  1. Whether the petitioners' motion to dismiss based on the unconstitutionality of Ordinance No. 7949 was valid.
  2. Whether the petitioners could appeal the trial court's order denying the motion to dismiss.
  3. Whether the petitioners followed the correct procedural remedy in challenging the trial court's order.

Arguments:

  • Petitioners' Arguments:

    • The petitioners contended that Ordinance No. 7949 was unconstitutional and cited the cases of Lagcao v. Labra and Jesus Is Lord Christian School Foundation, Inc. v. Municipality of Pasig to support their position.
    • They argued that the trial court's denial of their motion to dismiss was erroneous and warranted reconsideration.

  • Respondent's Arguments:

    • The City of Manila maintained that the petitioners' motion to dismiss lacked merit and that the trial court's ruling was correct.
    • The respondent emphasized that the petitioners failed to demonstrate how the cited cases were applicable to their situation and did not sufficiently explain the alleged unconstitutionality of the ordinance.

Court's Decision and Legal Reasoning:

The Supreme Court denied the petition, emphasizing that an order denying a motion to dismiss is interlocutory and not appealable. The Court clarified that such an order does not dispose of the case and allows it to proceed to final adjudication. The proper remedy for an aggrieved party in this situation is to file a special civil action for certiorari under Rule 65, not a petition for review on certiorari under Rule 45.

The Court further noted that even if the petition were treated as one for certiorari, it would still be dismissed due to a violation of the principle of hierarchy of courts. The petitioners should have filed their petition with the Court of Appeals rather than directly with the Supreme Court. The Court reiterated that direct recourse to the Supreme Court is only permissible under exceptional circumstances, which the petitioners failed to demonstrate.

Additionally, the Court found that the petitioners merely reiterated their previous arguments without providing substantial evidence or legal basis to support their claims regarding the unconstitutionality of the ordinance. The Court concluded that the petition did not present any issues of far-reaching implications or transcendental importance that would justify its treatment as a petition for prohibition or mandamus.

Significant Legal Principles Established:

  1. An order denying a motion to dismiss is interlocutory and not appealable; the proper remedy is a special civil action for certiorari.
  2. The principle of hierarchy of courts dictates that petitions for certiorari against Regional Trial Courts should be filed with the Court of Appeals, not directly with the Supreme Court.
  3. Direct recourse to the Supreme Court is only allowed in exceptional cases with compelling reasons.