G.R. No. 200804 - A.L. Ang Network, Inc. vs. Mondejar

On March 23, 2011, A.L. Ang Network, Inc. (petitioner) filed a complaint under the Rule of Procedure for Small Claims Cases before MTCC Branch 4, Bacolod City, seeking to collect ₱23,111.71 for unpaid water bills covering June 1, 2002 to September 30, 2005.
Petitioner alleged authorization to supply water and collect payments from homeowners of Regent Pearl Subdivision, including respondent Emma Mondejar, who consumed 1,150 cu.m. of water at agreed rates, and had paid only ₱5,468.38.

Respondent maintained that from April 1998 to February 2003, she paid a flat rate of ₱75.00 monthly, and that petitioner unilaterally imposed unreasonable rate adjustments without prior notice or HLURB approval.
Respondent questioned the basis of the ₱23,111.71 claim; petitioner had disconnected her water line for nonpayment from March 2003 to August 2005.

MTCC held that petitioner’s Certificate of Public Convenience from NWRB was only issued on August 7, 2003; thus, only the ₱75.00 flat rate applied pre-August 7, 2003, fully paid by respondent.
MTCC disregarded petitioner’s reliance on HLURB Decision for rate adjustments due to lack of proof of compliance with consultation directives and formal agreement; it continued the ₱75 rate for August 8, 2003 to September 30, 2005, found respondent owed ₱1,200 plus 6% interest.

Petitioner filed a Rule 65 certiorari petition before RTC Branch 45, Bacolod City, assailing the MTCC Decision as grave abuse of discretion.
On November 23, 2011, RTC dismissed the petition for certiorari, holding that small claims decisions are final and unappealable and that certiorari was an improper remedy to obtain a larger award; motion for reconsideration was denied on February 16, 2012.

Whether the RTC erred in dismissing petitioner’s recourse under Rule 65 of the Rules of Court as an improper remedy to challenge the MTCC’s small claims decision.