Case Digest (G.R. No. 205573)
Facts:
Helen Lorenzo Cunanan, petitioner, filed a Rule 65 petition with this Court challenging the Court of Appeals’ Ninth Division resolutions dated July 31, 2012 and November 26, 2012. (G.R. No. 205573, August 17, 2016, Supreme Court Second Division, Mendoza, J., writing for the Court.) The respondents in the underlying administrative proceeding were Yolanda Mercado (private respondent), who sought reallocation of an 800-square-meter home lot, and Teofilo Q. Inocencio, Regional Director, Department of Agrarian Reform Regional Office No. III (DAR‑R03); the Court of Appeals was also named as respondent in the present petition.On January 27, 2009, Mercado filed a petition for deallocation/reallocation of the home lot originally awarded to Alejandro Lorenzo (Cunanan’s father) before the DAR‑R03. The DAR‑R03 initially dismissed Mercado’s petition on April 8, 2010. Mercado moved for reconsideration (filed May 13, 2010), and on October 13, 2010 the DAR‑R03 granted reconsideration, recommending cancellation of Transfer Certificate of Title (TCT) No. 288509 issued in Cunanan’s name. An Order of Finality was issued by DAR‑R03 on December 1, 2010.
Cunanan only learned of the DAR’s October 13, 2010 order in April 2011. She then filed (1) a Motion to Quash the Order of Finality and other orders (May 13, 2011) alleging lack of notice and lack of DAR jurisdiction over her person; (2) a Petition for Relief from Judgment (June 13, 2011); and (3) a Petition for Injunction and Prohibition with prayer for Preliminary Injunction in the Court of Appeals (docketed CA‑G.R. SP No. 120083 on June 14, 2011) to prevent cancellation of her title and transfer to Mercado. The CA dismissed her injunctive petition on September 26, 2011 for failure to comply with procedural directives (deficient docket/legal fees, MCLE certificate date, proof of service), and its dismissal was certified final by Entry of Judgment on January 17, 2012.
Meanwhile, DAR‑R03, after receiving notice of the CA’s disposition, dismissed Cunanan’s Motion to Quash and Petition for Relief from Judgment as moot and academic in a March 9, 2012 Order; Cunanan’s motion for reconsideration was denied by DAR‑R03 on April 9, 2012. Cunanan then filed a petition for certiorari with the Court of Appeals (CA‑G.R. SP No. 125543) assailing DAR‑R03’s March 9 and April 9 orders as issued with grave abuse of discretion and for denial of due process; she also sought annulment of the DAR proceedings. The CA dismissed her certiorari petition by Resolution dated July 31, 2012, holding that the DAR acted in a quasi‑judicial capacity, that the proper remedy was by petition for review (the CA placed reliance on a time bar), and th...(Pro-only)
Issues:
- Whether the Court of Appeals’ July 31, 2012 and November 26, 2012 resolutions dismissing Cunanan’s petition for certiorari (CA‑G.R. SP No. 125543) are void for having been rendered with grave abuse of discretion amounting to lack or excess of jurisdiction and in deni...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)