Case Digest (G.R. No. L-13515)
Facts:
The case involves Paz Bacabac as the petitioner and appellant against Vicente F. Delfin, Gorgonio D. Drilon, and Paciencia Rafols as respondents and appellees. The events unfolded in Sagay, Occidental Negros, where on an unspecified date, Bacabac attempted to file a complaint for slight physical injuries against Rafols, who allegedly maltreated her twelve-year-old son. The acting Justice of the Peace, Francisco H. Ledesma, refused to docket the complaint, citing that it was not signed by the offended party or the chief of police. Consequently, Bacabac filed a mandamus action against Judge Ledesma in the Court of First Instance of Occidental Negros (Civil Case No. 3879). This case was later dismissed at Bacabac's request after Judge Ledesma accepted the complaint, which was then docketed as Criminal Case No. 1400 in the Justice of the Peace Court of Sagay.
On November 16, 1956, the incumbent Justice of the Peace, Gorgonio D. Drilon, inhibited himself from trying the cri...
Case Digest (G.R. No. L-13515)
Facts:
Initial Complaint and Refusal to Docket:
- Petitioner-appellant Paz Bacabac attempted to file a complaint for slight physical injuries against Paciencia Rafols in the Justice of the Peace Court of Sagay, Occidental Negros.
- The complaint alleged that Rafols maltreated Bacabac’s 12-year-old son.
- Acting Justice of the Peace Francisco H. Ledesma refused to docket the complaint because it was not signed by the offended party or the chief of police.
Mandamus Case and Dismissal:
- Bacabac filed a mandamus action in the Court of First Instance of Occidental Negros against Judge Ledesma (Civil Case No. 3879).
- The mandamus case was later dismissed by Bacabac herself after Judge Ledesma accepted and docketed the criminal case as Criminal Case No. 1400.
Judge Drilon’s Inhibition:
- Prior to the dismissal of the mandamus case, incumbent Justice of the Peace Gorgonio D. Drilon inhibited himself from trying Criminal Case No. 1400 because he was a respondent in the mandamus case.
- Executive Judge Jose Teodoro granted Drilon’s request for disqualification and designated Judge Vicente F. Delfin of the Justice of the Peace Court of Escalante to handle the case.
Motion to Quash and Dismissal:
- On December 12, 1956, the accused (Rafols) filed a motion to quash the criminal case, arguing that Bacabac had no authority to file the complaint and that the criminal action had prescribed.
- Bacabac opposed the motion and requested that Judge Delfin refrain from trying the case and that it be referred back to Judge Drilon.
- Judge Delfin granted the motion to quash and dismissed the case on December 27, 1956.
Certiorari and Mandamus Action:
- Instead of appealing the dismissal order, Bacabac filed a certiorari and mandamus action in the lower court against Judges Delfin and Drilon, as well as Paciencia Rafols.
- The lower court dismissed Bacabac’s petition, prompting the present appeal.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Substitution of Remedies: Certiorari and mandamus cannot be used as substitutes for the ordinary remedies available, such as reconsideration or appeal. Bacabac’s failure to exhaust these remedies barred her from seeking extraordinary relief.
- Finality of Orders: A final and executory order, such as the dismissal of the criminal case, cannot be challenged through certiorari. The proper remedy is an appeal, which must be timely filed.
- De Facto Judge Doctrine: Even if a judge’s designation is erroneous, their actions as a de facto judge are valid and binding, provided they acted within the scope of their authority.