Title
Supreme Court
Chong vs. Dela Cruz
Case
G.R. No. 184948
Decision Date
Jul 21, 2009
Petitioners challenged DOJ orders via certiorari; SC dismissed due to procedural lapses, hierarchy of courts violation, and lack of merit.

Case Digest (G.R. No. 184948)
Expanded Legal Reasoning Model

Facts:

  • Background
    • Petitioners: Cong. Glenn A. Chong, Mr. Charles Chong, and Mr. Romeo Arribe.
    • Respondents: Hon. Philip L. Dela Cruz, Hon. Romeo D.C. Galvez, Hon. Ramon “Chito” R. Mendoza (State Prosecutors), and Hon. Raul M. Gonzales, Secretary of Justice.
    • The case arose from the petitioners’ filing of a Rule 65 petition assailing the Joint Orders dated September 29, 2008, which were issued by the Department of Justice (DOJ).
  • Procedural History
    • The petitioners originally sought relief through a petition for certiorari with a prayer for a preliminary injunction and a restraining order.
    • The petition for certiorari was previously dismissed by this Court on November 17, 2008 due to lack of merit, compounded by technical defects.
    • The technical defects included:
      • Failure to state the material dates on the receipt of the assailed joint orders.
      • Non-compliance with the requirements for submitting legible duplicate original or certified true copies of the orders.
  • The Motion for Reconsideration
    • On January 29, 2009, the petitioners filed a Motion for Reconsideration challenging the Court’s prior resolution.
    • The motion sought the Court to re-evaluate its dismissal based on issues including non-observance of procedural rules.
  • Context of the Petition
    • The petitioners’ failure to comply with prescribed rules was highlighted as a significant factor.
    • In addition to procedural lapses, there was an issue regarding the proper course of recourse:
      • The petitioners directly sought the Supreme Court’s intervention rather than exhausting their appeal options with the Court of Appeals.
    • The case emphasizes the extraordinary nature of a petition for certiorari, which requires strict adherence to procedural rules and hierarchy of courts.

Issues:

  • Procedural Defects
    • Did the petitioners’ failure to include the material dates on receipt of the orders, as well as the lack of legible duplicate original or certified true copies, constitute grounds for dismissal?
    • Was there a violation of the specific rules in Section 4, Rule 65 and Section 3, Rule 46 of the Rules of Court?
  • Proper Forum and Hierarchy of Courts
    • Should the petitioners have availed themselves of recourse in the Court of Appeals before petitioning the Supreme Court?
    • Does the direct filing with the Supreme Court, bypassing the Court of Appeals, amount to an abuse of the proper hierarchical procedure?
  • Extraordinary Nature of the Petition for Certiorari
    • Is the petition for certiorari, which is classified as an extraordinary remedy, subject to a stricter standard of compliance with procedural requirements?
    • Were there any special or compelling circumstances in this case that would justify setting aside the procedural defects?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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