Title
A.L. Ang Network, Inc. vs. Mondejar
Case
G.R. No. 200804
Decision Date
Jan 22, 2014
Petitioner sought unpaid water bills from respondent, who disputed excessive charges. SC ruled certiorari available in small claims cases, reversing RTC dismissal.
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Case Digest (G.R. No. 200804)

Facts:

Background of the Case

  • Petitioner, A.L. Ang Network, Inc., filed a complaint for sum of money under the Rule of Procedure for Small Claims Cases before the Municipal Trial Court in Cities (MTCC) of Bacolod City. The complaint sought to collect P23,111.71 from respondent Emma Mondejar for unpaid water bills from June 1, 2002, to September 30, 2005.

Petitioner's Claim

  • Petitioner claimed it was authorized to supply water to Regent Pearl Subdivision, where respondent owned and occupied Lot 8, Block 3. Respondent consumed 1,150 cubic meters (cu. m.) of water during the period, amounting to P28,580.09 at the agreed rate of P113.00 for every 10 cu. m., plus P11.60 for every additional cu. m. Respondent paid only P5,468.38, leaving a balance of P23,111.71, which remained unpaid despite repeated demands.

Respondent's Defense

  • Respondent argued that from April 1998 to February 2003, she paid a monthly flat rate of P75.00 for water consumption. She claimed petitioner unilaterally imposed excessive adjustments without prior notice, charging her an average of 40 cu. m. per month, far above the average consumption for a household of three. She also questioned the basis of the P23,111.71 claim.

Water Disconnection

  • Petitioner disconnected respondent's water line from March 2003 to August 2005 due to non-payment of adjusted charges.

Issue:

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Ruling:

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Ratio:

  1. Availability of Certiorari in Small Claims Cases: While small claims decisions are final and unappealable under Section 23 of the Rule of Procedure for Small Claims Cases, certiorari under Rule 65 is available to correct jurisdictional errors. This remedy is not barred by the prohibition on appeals.
  2. Proper Forum for Certiorari: Certiorari petitions against first-level courts (e.g., MTCC) must be filed with the corresponding RTC, in line with the doctrine of hierarchy of courts and Section 4, Rule 65 of the Rules of Court.
  3. Jurisdictional Errors: The RTC should have evaluated whether the MTCC committed grave abuse of discretion in rendering its decision, rather than dismissing the petition outright. The RTC's dismissal was improper, as petitioner's recourse was valid and filed in the correct forum.


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