Facts:

The case involves petitioners-appellants Florentino and Adelina Enriquez, who are lessees of a residential house with a small store located at Lawaan St., Aurora Subdivision, Angono, Rizal. The property is owned by respondents-appellees, Nestor and Estrella Mijares. The dispute arose when the Enriquez spouses failed to pay their monthly rent from November 1975 to February 1976. In response, the Mijares sent several communications demanding payment and ultimately filed an ejectment case against the Enriquez spouses in the Municipal Court of Angono, Rizal, under Civil Case No. 117. The Enriquez spouses did not file an answer to the complaint but instead submitted motions to dismiss, which were denied by the municipal court. After filing an answer with a compulsory counterclaim, the Mijares moved to declare the Enriquez spouses in default, which the court granted, allowing Mijares to present evidence ex parte. The Enriquez spouses' subsequent motion for reconsideration was d...

Facts:

1. Parties Involved:

   • Petitioners-Appellants: Spouses Florentino and Adelina Enriquez, lessees of a residential house with a small store in Angono, Rizal.
   • Respondents-Appellees: Spouses Nestor and Estrella Mijares, owners of the property leased by the Enriquez spouses.

2. Lease Dispute:

   • The Enriquez spouses failed to pay monthly rentals from November 1975 to February 1976.
   • The Mijares spouses sent multiple communications demanding payment and vacating the premises, but the Enriquez spouses did not comply.

3. Ejectment Case:

   • The Mijares spouses filed Civil Case No. 117 for ejectment in the Municipal Court of Angono, Rizal.
   • Instead of filing an answer, the Enriquez spouses filed a motion to dismiss the complaint and later an amended motion to dismiss the amended complaint. Both motions were denied by the municipal court.
   • The Enriquez spouses eventually filed an answer with a compulsory counterclaim.
   • The municipal court declared the Enriquez spouses in default for failing to file a timely answer and proceeded to receive evidence ex parte.

4. Petition for Certiorari:

   • The Enriquez spouses filed Civil Case No. 23625 in the Court of First Instance (CFI), Branch XXVI of Rizal, seeking certiorari, prohibition, and preliminary injunction.
   • They argued that the municipal court acted without jurisdiction in:
     • Ordering the amendment of the complaint.
     • Denying their motion to dismiss the amended complaint.
     • Declaring them in default.
   • The CFI issued a restraining order halting the ejectment proceedings.

5. Municipal Court Decision:

   • While the certiorari petition was pending, the municipal court rendered a decision in favor of the Mijares spouses, ordering the Enriquez spouses to vacate the premises and pay back rentals, damages, and attorney’s fees.

6. Appeal and Dismissal:

   • The Enriquez spouses appealed the municipal court’s decision by filing Civil Case No. 24135 in the CFI.
   • The CFI dismissed the certiorari petition (Civil Case No. 23625) as moot and academic due to the pending appeal.
   • The CFI later dismissed the appeal in Civil Case No. 24135 because the Enriquez spouses had been declared in default and failed to seek the lifting of the default order.

7. Writ of Execution:

   • The Mijares spouses applied for and obtained a writ of execution, which was later set aside by the CFI.

8. Certification to the Supreme Court:

   • The Court of Appeals certified the case to the Supreme Court, as it involved a question of law.

Issue:

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Ruling:

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Ratio:

1. Certiorari as a Remedy of Last Resort:

   • Under Rule 65, Section 1 of the Rules of Court, certiorari is available only when there is no appeal or other plain, speedy, and adequate remedy.
   • Certiorari is not a substitute for appeal and is limited to correcting jurisdictional errors or grave abuse of discretion.

2. Appeal Renders Certiorari Moot:

   • The filing of an appeal in the same case (Civil Case No. 24135) made the certiorari petition unnecessary and moot.
   • The appeal provided an adequate remedy, and the certiorari petition lost its purpose.

3. Jurisdictional Errors and Procedural Mistakes:

   • Certiorari cannot be used to correct procedural errors or mistakes in the judge’s findings or conclusions.
   • The municipal court’s declaration of default and ex parte proceedings, even if erroneous, did not amount to a jurisdictional error or grave abuse of discretion.

4. Exceptions to the General Rule:

   • Certiorari may be allowed even if an appeal is available only in exceptional circumstances, such as when public welfare or broader interests of justice require it.
   • No such exceptional circumstances were present in this case.

Concurring Opinion (Justice Aquino)

• Justice Aquino concurred with the decision but noted that the municipal court erred in declaring the Enriquez spouses in default since they had filed an answer.
• He emphasized that the proper remedy for the Enriquez spouses was to move to set aside the default order and judgment, and if denied, to appeal.
• He also noted that the CFI erred in dismissing the appeal in Civil Case No. 24135 and should have remanded the case for a new trial. However, since the dismissal was final, nothing more could be done.