Facts:

The case involves Mocaral Macawiag as the petitioner and Judge Rasad Balindong and Soraida A. Macawiag as the respondents. The events leading to this case began with the marriage of Soraida Macawiag and Pangampong Macawiag on May 27, 1987, solemnized by Imam Macmod Ganzo. Prior to their marriage, it was agreed that the customary dower (mahr) would consist of P20,000.00 in cash, one head of live carabao, and a house and lot measuring 300 square meters located in Mahayahay, Iligan City, covered by Transfer Certificate of Title (TCT) No. T-28,147(a.f.). However, Mocaral Macawiag, the petitioner, and her children refused to acknowledge the house and lot as part of the mahr without valid grounds. Consequently, on October 27, 1998, Soraida filed a da'wa (a legal action) against Mocaral and her children in the Fourth Shari'a Circuit Court, seeking a declaration that the house and lot was indeed part of her mahr, along with damages and attorney's fees.

Before the filing...

Facts:

1. Marriage and Mahr Agreement

   • Private respondent Soraida Macawiag and Pangampong Macawiag were married on May 27, 1987.
   • Before the marriage, the representatives of the bride and groom agreed, and the solemnizing officer announced, that the customary dower (mahr) included P20,000.00 in cash, one head of live carabao, and a house and lot (300 square meters) located at Mahayahay, Iligan City, covered by Transfer Certificate of Title (TCT) No. T-28,147(a.f.).

2. Dispute Over Mahr

   • Despite the agreement, petitioner Mocaral Macawiag (Pangampong’s mother) and her children refused to recognize the house and lot as part of the mahr.
   • On October 27, 1998, Soraida filed a claim (da'wa) before the Fourth Shari'a Circuit Court, Iligan City, seeking:
     • Declaration that the house and lot is mahr property.
     • Change of title from Sarimanoc Macawiag to her name and her children.
     • Payment of damages and attorney’s fees.

3. Defense of Petitioner

   • Petitioner and her children admitted the marriage but denied that the mahr included the house and lot. They claimed the dowry was only P5,000.00 in cash.
   • They alleged the title to the house and lot was not lost but was used as collateral for a P500,000.00 loan, with P400,000.00 given to Pangampong, who failed to pay the amortization.

4. Trial Court Proceedings

   • Soraida presented witnesses, including the solemnizing officer (Imam Mahmod Ganzo), Pangampong Macawiag, and her mother, who corroborated the mahr agreement.
   • Petitioner and her witnesses denied the inclusion of the house and lot in the mahr and claimed it was mortgaged to Antonio Camama, who later executed a Deed of Absolute Sale.

5. Shari'a Circuit Court Decision

   • On April 13, 2000, the Shari'a Circuit Court ruled in favor of the petitioner, declaring the house and lot was not part of the mahr and ordering Soraida to pay P40,000.00 in attorney’s fees.

6. Shari'a District Court Decision

   • On appeal, the Shari'a District Court reversed the Circuit Court’s decision on March 14, 2003, declaring Soraida the exclusive owner of the house and lot as part of her mahr and ordering the petitioner to pay attorney’s fees and litigation expenses.

Issue:

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Ruling:

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Ratio:

1. Jurisdiction and Errors of Judgment

   • Errors committed by a court in the exercise of its jurisdiction are errors of judgment, not errors of jurisdiction. Certiorari under Rule 65 is not the proper remedy for correcting errors of judgment.

2. Finality of Decisions

   • A decision that has become final and executory can no longer be reviewed, even by the Supreme Court, to ensure the orderly administration of justice and the finality of litigation.

3. Hierarchy of Courts and Proper Remedies

   • The rule on hierarchy of courts must be observed. Aggrieved parties must exhaust the proper remedies (e.g., appeal) before resorting to extraordinary remedies like certiorari.

4. Procedural Rules and Substantive Justice

   • While procedural rules may be relaxed to achieve substantial justice, litigants must still comply with the prescribed procedures and provide valid reasons for any non-compliance.