G.R. No. 208912 - Aquino vs. Aquino

On October 22, 1996, private respondent Juan Marcos Arellano, Jr. filed a complaint with the Regional Trial Court (RTC), Pasig City, for the collection of a sum of money.
On November 12, 1996, petitioner Nilo H. Raymundo filed his answer with counterclaim to the complaint.

The RTC scheduled an initial pre-trial conference on January 7, 1997, at 9:00 a.m.
The pre-trial was postponed due to petitioner’s motion for leave to file an amended answer.
On January 9, 1997, petitioner submitted an amended answer with counterclaim along with a manifestation.
Private respondent filed an opposition to the admission of the amended answer, to which petitioner later replied.
On February 24, 1997, the trial court issued an order striking out petitioner’s manifestation and amended answer with counterclaim for non-compliance with Section 3, Rule 10 of the Rules of Court.

A subsequent pre-trial conference was scheduled on March 5, 1997, at 8:30 a.m., conditional on the resolution of the motion to admit the amended answer.
Petitioner, awaiting the resolution of his motion, did not attend the March 5 conference.
Later on March 5, 1997, the trial court declared petitioner in default for non-appearance and allowed respondent to present evidence ex-parte the following day.

On March 6, 1997, petitioner filed an urgent motion to set aside the default order.
Despite the motion, the trial court proceeded to receive respondent’s evidence ex-parte.
On March 7, 1997, petitioner filed a motion to set aside the evidence procured ex-parte from respondent.

On September 3, 1997, the RTC rendered its decision without resolving petitioner’s pending motions to set aside the default order and the ex-parte evidence.
The decision rendered judgment in favor of respondent, ordering petitioner to pay:

A principal amount of P3,625,000.00 with legal interest from October 1, 1996, until fully paid;
P15,000.00 as moral damages;
P10,000.00 as exemplary damages;
25% of the amount recovered by way of attorney’s fees;
The cost of suit.

On October 15, 1997, petitioner filed a motion for reconsideration; respondent opposed the motion.
On November 14, 1997, petitioner filed an “aad cautelama omnibus” petition for relief from judgment or order.
On May 12, 1998, the RTC denied petitioner’s motions for reconsideration and the omnibus petition.
On May 28, 1998, petitioner filed a notice of appeal to the Court of Appeals, which was approved on June 9, 1998.
On July 16, 1998, petitioner commenced a special civil action for certiorari before the Court of Appeals challenging the validity of the RTC’s decisions and proceedings.
On February 19, 1999, the Court of Appeals dismissed the petition on certiorari, stating that certiorari lies only when no plain, speedy, or adequate appellate remedy exists, emphasizing that an appeal remains the proper remedy.
Petitioner argued that even though an appeal was available, it was inadequate given that the disputed orders were rendered in excess of jurisdiction, and the refusal to set aside the motions amounted to a grave abuse of discretion.
On June 14, 1999, the Supreme Court directed respondents to comment on the petition.
On July 20, 1999, respondent filed his comment.
Ultimately, the Supreme Court granted the petition for certiorari, reversed and set aside the Court of Appeals’ resolution, and remanded the case to the RTC for further proceedings.

Whether the Court of Appeals erred in denying petitioner’s petition for certiorari on the ground that an appeal was available as a remedy.
Whether the trial court’s failure to resolve petitioner’s motions to set aside the default order and the ex-parte evidence constituted a grave abuse of discretion, thereby justifying the intervention of certiorari.
Whether an ordinary appeal is a sufficient remedy to redress the procedural and discretionary errors committed by the trial court, or if the exceptional circumstances warranted the extraordinary remedy of certiorari.